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Central Electricity Regulatory Commission
New Delhi
Coram:
Shri P.K. Pujari, Chairperson
Shri M.K. Iyer, Member
No.–L-1/(3)/2009-CERC Date:9
th
January, 2019
In matter of
Central Electricity Regulatory Commission (Grant of Connectivity, Long-term Access
and Medium-term Open Access in inter-State Transmission and related matters)
(Seventh Amendment) Regulations, 2018
Statement of Reasons (SoR)
1. Introduction
1.1. The Commission vide notification dated 9.8.2018 issued the Draft Central
Electricity Regulatory Commission (Grant of Connectivity, Long-term Access
and Medium-term Open Access in inter-State Transmission and related
matters) (Seventh Amendment) Regulations, 2018 along with Explanatory
Memorandum seeking comments/ suggestions/ observations from the
stakeholders/public.
1.2. Comments were received from 17stakeholders and organizations, which
included State Power utilities, Central Transmission Utility (CTU), Solar
Energy Corporation of India Ltd. (SECI),The Energy and Research Institute
(TERI),renewable energy generating companies and associations.
Thereafter, the Commission conducted public hearing on 19.9.2018. Four
(04) organizations/individuals made oral submissions or presentations during
the public hearing. List of stakeholders/individuals who submitted written
comments and who made oral submissions/power point presentation during
the public hearing is given at Appendix-I & Appendix-II respectively. The
detailed comments are available on www.cercind.gov.in.After due
considerations of the comments/ suggestions/ objections received, the
Commission has finalized the Seventh Amendment to the Connectivity
Regulations.
1.3. The amendments proposed in the draft regulations, deliberation on the
comments/suggestions offered by the stakeholders, statutory bodies and
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association, etc., on the proposed amendments and the reasons for
decisions of the Commission are given in the succeeding paragraphs. While
an attempt has been made to consider all the comments/suggestions
received, the names of all the stakeholders may not appear in the
deliberations. However, the name of all the stakeholders is enclosed as
Appendix-I and II.
2. The Commission while proposing the amendments in provisions related to
, had given following rationale:
1. Provisions related to „Applicant‟ in respect of grant of Connectivity
1.1. The Ministry of New & Renewable Energy (MNRE) has vide notification
No. 238/78/2017-Wind dated 14
th
-Solar
connected wind solar PV hybrid system for optimal and efficient utilization of
transmission infrastructure and land, reducing the variability in renewable
power generation and achieving better grid stability. The relevant portion of
the said hybrid policy dated 14th May, 2018 is reproduced as under:
1.1 India has set an ambitious target of reaching 175 GW of installed capacity
from renewable energy sources by the year 2022, which includes 100 GW of
solar and 60 GW of wind power capacity. Various policy initiatives have been
taken to achieve this target. At the end of 2017-18 the total renewable power
installed capacity in the country was almost 70 GW.
1.2 Solar and wind power being variable in nature pose certain challenges on
grid security and stability. Studies revealed that in India solar and wind
resources are complementary to each other and hybridization of these two
technologies would help in minimizing the variability apart from optimally
utilizing the infrastructure including land and transmission system.
1.3 Superimposition of wind and solar resource maps shows that there are
large areas where both wind and solar have high to moderate potential.
1.4 The existing wind farms have scope of adding solar PV capacity and
similarly there may be wind potential in the vicinity of existing solar PV plant.
1.5 Suitable policy interventions are therefore, required not only for new wind-
solar hybrid plants but also for encouraging hybridization of existing wind and
solar plants.
1.6 To smoothen the wind solar hybrid power further, appropriate capacity of
battery storage may also be added to the project.
2. AIMS AND OBJECTIVE
2.1 The main objective of the Policy is to provide a framework for promotion of
large grid connected wind-solar PV hybrid system for optimal and efficient
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utilization of transmission infrastructure and land, reducing the variability in
renewable power generation and achieving better grid stability.
2.2 Policy also aims to encourage new technologies, methods and wayouts
involving combined operation of wind and solar PV plants.
3. PERIOD OF ENFORCEMENT
This policy will remain in force unless withdrawn, modified or superseded by
the Government. The Government will undertake a review of this Policy as and
when required.
4. WIND-SOLAR HYBRID SYSTEMS
4.1 Under the category of wind-solar hybrid power plants, Wind Turbine
Generators (WTGs) and Solar PV systems will be configured to operate at the
same point of grid connection. There can be different approaches towards
integrating wind and solar depending upon the size of each of the source
integrated and the technology type.
4.2 In case of fixed speed wind turbines connected to grid using an induction
generator, the integration can be on the HT side at the AC output bus.
However, in case of variable speed wind turbines deploying inverters for
connecting the generator to the grid, the wind and the Solar PV system can be
connected to the intermediate DC bus of the AC-DC-AC converter.
4.3 The second important aspect would be related to the sizing which would
depend on the resource characteristics. In order to achieve the benefits of
hybrid plant in terms of optimal and efficient utilization of transmission
infrastructure and better grid stability by reducing the variability in renewable
power generation, in the locations where the wind power density is quite good,
the size of the solar PVs capacity to be added as the solar-hybrid component
could be relatively smaller. On the other hand, in case of the sites where the
wind power density is relatively lower or moderate, the component of the solar
PV capacity could be relatively on a higher side.
However, a wind-solar plant will be recognized as hybrid plant if the rated
power capacity of one resource is at least 25% of the rated power capacity of
other resource. .................
5.4 Battery Storage:
Battery storage may be added to the hybrid project (i) to reduce the variability
of output power from wind solar hybrid plant; (ii) providing higher energy
output for a given capacity (bid/ sanctioned capacity) at delivery point, by
installing additional capacity of wind and solar power in a wind solar hybrid
plant; and (iii) ensuring availability of firm power for a particular period.
Bidding factors for wind solar hybrid plants with battery storage may include
minimum firm power output throughout the day or for defined hours during the
day, extent of variability allowed in output power, unit price of electricity,
1.2. Accordingly, any company authorized by Central/State Government as
Wind/Wind-Solar Power Park developer, generation projects based on
renewable energy source including hybrid project based on renewable and
storage has been proposed as an applicant eligible for grant of Connectivity
or Access. The project based on storage can be of any technology such as
Mechanical storage systems (Pumped hydro storage (PHS), Compressed air
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energy storage (CAES), Fly wheel energy storage (FES)), Electro-chemical
storage systems (Secondary batteries, Flow batteries), Chemical energy
storage (Hydrogen (H2), Synthetic natural gas (SNG)), Electrical storage
systems (Double-layer capacitors (DLC), Superconducting magnetic energy
storage (SMES)), Thermal storage systems, etc.
1.3. Further, for the integration of renewable energy generation into the grid,
Storage plants can help ensuring availability of firm power from the
renewable project. Therefore, it has been proposed to include storage plants
(irrespective of technology used) of installed capacity 50MW and above as
applicant eligible for grant of Connectivity. Such standalone storage may
draw power from the grid. For example, in pumped hydro storage (PHS)
water is released from the high reservoir through a hydroelectric turbine into
the low reservoir to generate electricity during demand and power from the
grid is drawn to pump water from a reservoir up to another reservoir at a
higher elevation. Therefore, it has been proposed that PHS will apply for
connectivity for the quantum of maximum injection or maximum drawal,
whichever is higher, and sign separate agreements for both injection and
drawal of power.
1.4. In case of hybrid wind-solar or wind-solar-storage projects, the
aggregate power supplied from the project may be lesser than the combined
installed capacity of wind and solar of the hybrid plant. Considering the same,
the developer of the hybrid wind-solar or wind-solar-storage projects may
apply for connectivity quantum based on assessed aggregate power supplied
from the project which may be lesser than combined installed capacity of
wind and solar of the hybrid plant. In such cases, the hybrid plant developer
shall maintain power injection into the grid upto the requested connectivity
quantum.
1.5. Based on above discussions, amendments have been proposed to sub
clause (b)(i)(a), (b)(i)(b), (b)(i)(c), (b)(i)(e) and (b)(i)(f). Further, sub-clause
(b)(i)(aa), has been added after clause (b)(i)(a), sub-clause (b)(i)(cc), has
been added after clause (b)(i)(c) and a new sub-clause (b)(i)(h) have been
added in clause (1) of Regulation 2 of the Principal Regulations
3. Amendment sub-clause (b)(i)(a) of Clause (1) of Regulation 2 of the
Principal Regulations:
3.1. The sub-clause (b)(i)(a) of Clause (1) of Regulation 2 of the Principal
Regulations was proposed to be substituted as under:
Energy Generating
station, with installed capacity of 250 MW and above, including a captive
generating plant of exportable capacity of 250 MW and above or;
3.2. Comments have been received from GRIDCO and TERI:
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3.2.1.
regulations as the generation capacity available with a captive generating
plant for sale after accounting for the consumption by its captive user and/
generation capacity intended for wheeling of power to its plant located at
non-contiguous place. GRIDCO has also suggested that in case of CGP
having captive load at a different geographical place than its generating unit,
the maximum exportable capacity equal to installed capacity less auxiliary
consumption should be considered for applying connectivity to ISTS.
3.2.2. TERI has suggested adding
the regulations as a power plant fulfilling the conditions of CGP as
prescribed under Electricity Rules, 2005.
3.3. Analysis and decision
3.3.1.
instant regulations, it is clarified that the Commission has issued draft CERC
(Grant of Connectivity and General Network Access to the inter-State
transmission system and other related matters) Regulations, 2017hereinafter
called as Draft GNA Regulations vide public notice on 14.11.2017 wherein
definition has been proposed as under:
ns the generation capacity available
with a captive generating plant for sale after accounting for the
consumption by its captive user
Since, the Commission is in the process of finalizing the Draft GNA
Regulations; the comments submitted by GRIDCO shall be duly taken care
while finalising the same.
3.3.2. Regarding suggestion of TERI to define Captive Generating Plant (CGP)as
prescribed under Electricity Rules, 2005, it is clarified that the Captive
generating plantis defined at Clause (8) of Section 2 in the Electricity Act,
2003 as under:
person to generate electricity primarily for his own use and includes a
power plant set up by any co-operative society or association of
persons for generating electricity primarily for use of members of such
cooperative society or association;
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Further, Clause 3 of the Electricity Rules, 2005
.
Also, Regulation 2(2) of the instant Regulations provides as under
(2) Words and expressions used in these regulations and not defined
herein but defined in the Act or the Grid Code or any other regulations
specified by the Commission shall, unless the context otherwise
requires, have the meanings assigned to them under the Act or the Grid
Code or other regulations specified by the Commission, as the case
may be.
Hence, Captive generating plant
defined in the
Electricity Rules, 2005 shall also be applicable in the instant Regulations.
3.4. Accordingly, the sub-clause (b)(i)(a) of Clause (1) of Regulation 2 of the
Principal Regulations shall be substituted as proposed in the draft as under:
erating station other than Renewable Energy Generating
station, with installed capacity of 250 MW and above, including a captive
generating plant of exportable capacity of 250 MW and above or;
4. Addition of a newsub-clause after sub-clause (b)(i)(a) of Clause (1) of
Regulation 2 of the Principal Regulations:
4.1. The following sub-clause was proposed to be added after sub-clause
(b)(i)(a) of clause (1) of Regulation 2 of the Principal Regulations, namely:
installed capacity of 50
MW and above, or;
4.2. Comments have been received from Greenko, GRIDCO and
TANGEDCO:
4.2.1. Greenko has submitted that Renewable Power Developer and Renewable
Power Park Developer having installed capacity of 50MW and above should
also be allowed for grant of Connectivity.
4.2.2. GRIDCO and TANGEDCO have submitted that the minimum qualifying
criteria for RE generating stations to be connected to ISTS as 50MW of
installed capacity will severely skew the transmission system optimality. It
will not only infuse inefficiency in terms of huge stranded /redundant
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transmission asset creation at ISTS level but will pose humongous financial
burden on existing DICs as well, as RE generators availing ISTS connectivity
are waived from transmission charge payment as per MoP order. Hence, in
order to have an efficient & economic transmission system in place, as
mandated under the EA 2003, the minimum limit of RE installed capacity
(either individually or in group aggregate) for ISTS connectivity should be
250 MW. Anything less than 250 MW may be tied up with intra-state network
under coordinated planning to be carried out by CTU/CEA/STU and
DISCOMs as per the CERC (Planning, Coordination and Development of
Economic and Efficient Inter-State Transmission System by Central
Transmission Utility and other related matters) Regulations, 2018. It will not
only avoid redundant transmission capacity creation but also help to develop
planned robust Intra State transmission system giving effect to distributed
energy sources.
4.3. Analysis and decision:
4.3.1. Withregard to suggestion of Greenko to allow Renewable Power Developer
and Renewable power park developer having installed capacity of 50MW or
more, it is clarified that Renewable Power Developer is same as Renewable
Energy Generating Station. Renewable Energy Generating Station are
already eligible to apply Connectivity under the various sub-clauses (b)(i) of
clause (1) of Regulation 2. Renewable Power Park Developer as authorized
by the Central Government or the State Government shall be eligible for
grant of Connectivity. We have perused Guidelines for Tariff Based
Competitive Bidding Process for Grid Connected Small Hydro Power
(SHP) Projects above 10 MW Station Capacity” which provides as follows:
Consortium
submitting the Bid. Any reference to the Bidder includes Bidding Company /
Bidding Consortium/ Consortium, Member of a Bidding Consortium including
its successors, executors and permitted assigns and Lead Member of the
Bidding Consortium jointly
We observe that such a project developer shall be responsible for
establishing the generating station and hence shall be covered under
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relevant Clause of Regulation 2(1)(b). Hence we donot find any need to
separately include Renewable Power Developer under definitions.
4.3.2. Regarding suggestions of GRIDCO and TANGEDCO onminimum qualifying
criteria for RE generating stations to be modified as250MW, it is clarified that
minimum MW for Connectivity to ISTS as 50 MW was proposed vide draft
amendment to CERC Connectivity Regulationson 15.5.2010. The relevant
portion of the Explanatory Memorandum to said amendment dated
15.5.2010 is reproduced as under:
3. Subsequent to the operation of the regulations, a number of Private
developers of Hydro Power in the North Eastern Region represented to
the Commission that their projects which are mostly below 250 MW are
deprived of connectivity to the ISTS on account of Regulation 2(1)(b)(i)
which requires the installed capacity of 250 MW and above for
connectivity. Moreover, the State Transmission Utilities are slow in
developing the required transmission infrastructure in the region. Similar
requests have been received from other developers also. It has also
been brought to the notice of the Commission that Central Electricity
Authority in consultation with Central Transmission Utility and State
Transmission Utilities had planned and finalized the transmission
schemes for evacuation of power from a number of hydro projects,
particularly in Sikkim, Himachal Pradesh and Arunachal Pradesh wherein
it was intended to connect a number of medium size hydro projects of
capacity below 250 MW directly to the Powergrid pooling points.
Moreover, the State Transmission Utilities of Sikkim and Arunachal
Pradesh are not geared up to provide transmission facilities to the IPPs.
The load demands in these states being small, most of the power
generated from these IPPs would have to be exported out of these
States.
4. The Commission after considering the problems of the Hydro
generating companies and to bring more power to the National Grid, has
decided that the hydro generating projects having an installed capacity of
50 MW and above be allowed connectivity to the ISTS. Accordingly, the
amended to provide connectivity to hydro projects of 50 MW and above.
The Commission after considering the comments/suggestions given by
stakeholders notified the amendment vide notification dated 3
rd
September,
2010wherein, the threshold capacity for connecting to inter-State grid was
reduced from 250 MW to 50 MW for the generating stations using
Renewable sources of energy& hydro generating stations. Further vide the
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instant amendment, the minimum quantum required for connectivity to ISTS
was not proposed to be changed. We are not inclined to increase the
minimum quantum as 250 MW.
4.4. Accordingly, following sub-clause shall be added after sub-clause (b)(i)(a) of
clause (1) of Regulation 2 of the Principal Regulations:
station with installed capacity of 50
MW and above, or;
5. Amendment in sub-clause (b)(i)(b) of Clause (1) of Regulation 2 of the
Principal Regulations:
5.1. The sub-clause (b)(i)(b) of Clause (1) of Regulation 2 of the Principal
Regulations was proposed to be substituted as under:
250 MW
5.2. Comments have been received from Greenko:
5.2.1. Greenko has submitted to include standalone storage projects also in the
proposed amendment.
5.3. Analysis and decision:
5.3.1. With regard to suggestion of Greenko, the project based on standalone
storage source(s)of installed capacity 50MW and above has already been
proposed for grant of Connectivity under sub-clause (b)(i)(h) of Clause (1) of
Regulation 2.
5.4. In view of above discussion, the sub-clause (b)(i)(b) of Clause (1) of
Regulation 2 of the Principal Regulations shall be substituted as under:
A Hydro Generating station of installed capacity between 50 MW and
250 MW
6. Amendment in sub-clause (b)(i)(c) of Clause (1) of Regulation 2 of the
Principal Regulations:
6.1. The sub-clause (b)(i)(c) of Clause (1) of Regulation 2 of the Principal
Regulations was proposed to be substituted as under:
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individually having less than 50 MW installed capacity, but collectively
having an aggregate installed capacity of 50 MW and above, and acting
on behalf of all these generating stations, and seeking connection from
CTU at a single connection point at the pooling sub-station under CTU,
6.2. Comments have been received from MSEDCL, MPPMCL, Greenko and
TANGEDCO:
6.2.1. MSEDCL has submitted that standalone storage project should be allowed
to apply for connectivity only after identification of beneficiaries and signing
of commercial agreement between them for settlement for power drawn &
injected.
6.2.2. MPPMCL has submitted that the Standalone storage project should be
defined to avoid ambiguity.
6.2.3. Greenko has suggested that standalone storage project may also act as the
lead generator.
6.3. Analysis and decision:
6.3.1. With regard to suggestion of MSEDCL that firm beneficiary should be
identified in advance for grant of Connectivity cannot be accepted as there is
no such condition for grant of Connectivity under the extent Regulations for
other types of projects.
6.3.2. We agree with suggestion of Greenko and it is already covered in the
Regulations.
6.3.3. MPPMCL has suggested that standalone storage project should be defined
to avoid ambiguity. In this regard it is clarified that is defined in
these Regulations and a project based on such storage technology shall be
covered under standalone storage project.
6.3.4.
6.4. Accordingly, sub-clause (b)(i)(c) of Clause (1) of Regulation 2 of the Principal
Regulations shall be substituted as under:
individually having less than 50 MW installed capacity, but collectively
having an aggregate installed capacity of 50 MW and above, and acting
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on behalf of all these generating stations or standalone storage project,
and seeking connection from CTU at a single connection point at the
pooling sub-station forming part of ISTS, termed as the lead generator,
7. Addition of a newsub-clause after sub-clause (b)(i)(c) of Clause (1) of
Regulation 2 of the Principal Regulations:
7.1. The following sub-clause was proposed to be added after sub-clause (b)(i)(c)
of clause (1) of Regulation 2 of the Principal Regulations, namely:
ess than
50 MW installed capacity, but collectively having an aggregate installed
capacity of 50 MW and above, and acting on behalf of all these
generating stations, and seeking connection from CTU at a single
connection point at the pooling sub-station under CTU, termed as the
7.2. Comments have been received from AGEL, Greenko, InWEA, MPPMCL,
TANGEDCO and TERI:
7.2.1. AGEL has submitted that for efficient utilization of infrastructure, sharing of
connectivity and Dedicated Transmission Infrastructure has been proposed
to be allowed in the Connectivity Procedure. Considering the same, we
suggest following changes in the existing clause as under:
"(cc) Renewable Energy generating station individually having any installed
capacity, but collectively having an aggregate installed capacity of 50 MW and
above, and acting on behalf of all these generating stations, and seeking
connection from CTU at a single connection point at the pooling sub-station
under CTU, termed as the lead gener
This shall allow even projects with collective capacity lower than the
Bay/Dedicated Transmission Line capacity, irrespective of their individual
capacity (whether lower than 50 MW or higher than 50 MW), one of them
can apply as lead generator and connectivity can be granted to them for
efficient utilization of Transmission Infrastructure.
7.2.2. Greenko has suggested that the proposed regulation may be modified to
include Renewable Power Developer, Renewable Power Park Developer
and Standalone storage Park Developer also.
7.2.3. InWEA has submitted that Renewable Power Park Developer may also be in
such a situation like a generating company and has suggested that
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Renewable Power Park Developer may also be included in the instant
provision.
7.2.4. MPPMCL has suggested as under:
Renewable Energy generating station individually having less than 50
MW installed capacity, but collectively having an aggregate installed
capacity of 50 MW and above, and one of them acting on behalf of all
these generating stations, and seeking connection from CTU at a single
connection point at the pooling sub-station under CTU, termed as the
lead generator
7.2.5. TERI has suggested that the words 'under CTU' may be substituted with
'forming a part of ISTS'
7.3. Analysis and decision:
7.3.1. The submissions of AGEL to allow Renewable Energy generating station
individually having any installed capacity but collectively having an
aggregate capacity of 50MW and above are already covered under extant
provisions.
7.3.2. With regard to suggestion of Greenko to include Renewable Power
Developer, it is clarified that both Renewable Power Developer and
Renewable Energy Generating Stations are same and already covered
under Regulation 2(1)(b)(i)(cc). Further, with regard to Standalone Storage
Park Developer, it is clarified that company or entity authorised by the
Central Government or State Government as Renewable Power Park
Developer were proposed for grant of Connectivity in these Regulations.
With regard to suggestion of InWEA regarding inclusion of Renewable
Power Park Developer in the instant provision, it is clarified that the same
are already coveredunder sub-clause (b)(i)(f) of clause (1) of Regulation 2
and shall be as authorised by Central or State Government.
7.3.3. We agree with the suggestion of TERI and MPPMCL and changes have
been made accordingly.
7.3.4. In view of following discussion, following sub-clause shall be added after
sub-clause (b)(i)(c) of clause (1) of Regulation 2 of the Principal Regulations:
50 MW installed capacity, but collectively having an aggregate installed
capacity of 50 MW and above, and one of them acting on behalf of all
these generating stations, and seeking connection from CTU at a single
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connection point at the pooling sub-station forming part of ISTS, termed
8. Amendment in sub-clause (b)(i)(e) of Clause (1) of Regulation 2 of the
Principal Regulations:
8.1. The sub-clause (b)(i)(e) of Clause (1) of Regulation 2 of the Principal
Regulations was proposed to be substituted as under:
above developed by a generating company in its existing generating
station of the description referred to in sub-clauses (b)(i)(a) to (cc) of this
clause and seeking connectivity to the existing connection point with
inter-State Transmission System through the electrical system of the
generating station subject to availability of Connectivity capacity in
8.2. Comments have been received from InWEA, MSEDCL and NTPC:
8.2.1. MSEDCL has submitted that CUF of RE generating station is normally very
low & there will be always margin available in Transmission system. Hence
CTU should not be allowed alone to take decision for granting connectivity in
such case; rather procedure as outlined in CERC (Planning, Coordination
and Development of Economic and Efficient Inter-State Transmission
System by Central Transmission Utility and other related matters)
Regulations, 2018 shall be followed.
8.2.2. NTPC has submitted that the Ministry of Power, Government of India vide
letter dated 5.4.2018 has issued detailed mechanism for allowing flexibility in
generation and scheduling of thermal power stations to reduce emissions.
The scheme provides flexibility to the generating company of using its
thermal power or renewable power to meet its scheduled generation from
that thermal generating station. The generating company may either
establish or procure renewable energy from anywhere in the country and
Connectivity to the ISTS for RE generating station shall be applied as per the
extant Regulations. RE generating stations of installed capacity less than 5
MW seeking connectivity through electrical system of existing generating
station can also be developed. Further, RE generating stations outside the
premises of the existing thermal station but located at the nearby locations
can be connected through the electrical system of the existing thermal
station. Hence, Renewable Energy Generating Station of capacity 1MW and
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above seeking connectivity to existing connection point with ISTS through
electrical system of existing generating company should be allowed
connectivity.
8.2.3. InWEA has submitted that Renewable Park Developer should have the
same rights as a generating company as WPPD has the right to get
connectivity and commission the generating station.
8.3. Analysis and decision:
8.3.1. Regarding submission of NTPC that Renewable Energy Generating Station
of capacity 1MW and above seeking connectivity to existing connection point
with ISTS through electrical system of existing generating company should
be allowed connectivity, it is clarified that the minimum capacity of 5MW
required for RE generating station seeking connectivity to the existing
connection point with ISTS through electrical system of existing generating
station was not proposed to be changed in the instant amendment. Hence,
we are not inclined to amend the minimum capacity to be allowed under this
Clause. However, it is clarified that generation capacity less than 5MW shall
be allowed to get connected to electrical system of existing generating
station subject to condition that the Connectivity granted to existing
generating station shall remain same and the existing generating station
shall inform CTU in this regard atleast3 months prior to the intended
connection.
8.3.2. The suggestion of NTPC that connectivity for projects that may not be
located in its existing generating station but may be located outside the
premises of such generating station and wish to get connected through
electrical system of existing generating station is acceptable and regulations
have been modified to include this suggestion.
8.3.3. We agree with submission of MSEDCL that CTU should follow the procedure
as outlined in CERC (Planning, Coordination and Development of Economic
and Efficient Inter-State Transmission System by Central Transmission
Utility and other related matters) Regulations, 2018.
8.3.4. We agree with the suggestion of InWEA and hence, to facilitate connectivity
to a renewable energy generating station of 5MW and above developed in
the existing Renewable Power Park, a new provision has been incorporated
at Regulation 2(b)(i)(ee) in the existing Regulations as under:
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ee) Any renewable energy generating station of 5 MW capacity and
above developed by a Renewable power park developer in its existing
power park of the description referred to in sub-clauses (b)(i)(g) of this
clause and seeking connectivity to the existing connection point with
inter-State Transmission System through the electrical system of the
Renewable Power Park subject to availability of Connectivity capacity in
existing Power Park
8.3.5. In view of above discussion, the sub-clause (b)(i)(e) of Clause (1) of
Regulation 2 of the Principal Regulations shall be substituted as under:
above developed by a generating company in its existing generating
station or near its existing generating station of the description referred to
in sub-clauses (b)(i)(a) to (cc) of this clause and seeking connectivity to
the existing connection point with inter-State Transmission System
through the electrical system of the generating station subject to
availability of Connectivity capacity in existing station as assessed by
9. Amendment in sub-clause (b)(i)(f) of Clause (1) of Regulation 2 of the
Principal Regulations:
9.1. The sub-clause (b)(i)(f) of Clause (1) of Regulation 2 of the Principal
Regulations was proposed to be substituted as under:
9.2. Comments have been received from Greenko:
9.2.1. Greenko has suggested to include Central or State Government authorized
Standalone Storage Park Developer for grant of connectivity.
9.3. Analysis and decision:
9.3.1. The suggestion of Greenko is outside the scope of present amendment.
9.3.2. In view of the above discussion, sub-clause (b)(i)(f) of Clause (1) of
Regulation 2 of the Principal Regulations shall be substituted as under:
State Government as Renewable Power Park developer
10. Addition of two sub-clauses after sub-clause (b)(i)(f) of Clause (1) of
Regulation 2 of the Principal Regulations:
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10.1. The following two sub-clauses was proposed to be added after sub-clause
(b)(i)(f) of clause (1) of Regulation 2 of the Principal Regulations, namely:
State Government as Implementing Agency on behalf of the Renewable
Power Developers who are eligible for grant of connectivity under Clause
2(1)(b)(i)(aa) and 2(1)(b)(i)(cc) or;
(h) A Project Developer based on standalone storage source(s) of
installed capacit
10.2. Commission had given following rationale while proposing the above
amendment:
1.3. Further, for the integration of renewable energy generation into the
grid, Storage plants can help ensuring availability of firm power from the
renewable project. Therefore, it has been proposed to include storage
plants (irrespective of technology used) of installed capacity 50MW and
above as applicant eligible for grant of Connectivity. Such standalone
storage may draw power from the grid. For example, in pumped hydro
storage (PHS) water is released from the high reservoir through a
hydroelectric turbine into the low reservoir to generate electricity during
demand and power from the grid is drawn to pump water from a reservoir
up to another reservoir at a higher elevation. Therefore, it has been
proposed that PHS will apply for connectivity for the quantum of
maximum injection or maximum drawal, whichever is higher, and sign
separate agreements for both injection and drawal of power.
1.6. SECI has vide letter dated 21.4.2018 submitted that it is the
designated implementing agency for the MNRE grid connected wind and
solar scheme and requested the Commission to allow it to take
connectivity as Implementing Agency on behalf of SPDs/WPDs
shortlisted through competitive bidding. The relevant portion of
suggestion given by SECI is reproduced as under:
connected wind and Solar scheme. The scheme aims to provide wind
and solar power at very competitive rates to obligated states/UTs to
fulfill RPO obligations.
As per provisions of scheme, SECI will select developers through a
transparent bidding process, purchase power from the selected
developers and sell the same to utilities. PPA and PSA are valid for
min. period of 25 years from the date of commissioning of 1
st
Unit.
Page 17
Apart from above, S
monitoring, and also successful commissioning of project through
standard commissioning procedure including declaration of COD.
In view of above, it is pertinent to mention that SECIs role is not
limited to signing of PPA, PSA but also doing all activities for
successful implementation of project.
We would Ike to request Honourable Commission to allow SECI to
take connectivity on behalf of SPDs/WPDs shortlisted through
competitive bidding as implementing agency o
1.7. SECI has vide letter dated 21.4.2018 further submitted that the
present regulation does not allow implementing agency to apply for
connectivity and transfer connectivity right to the generator selected for
implementation of solar or wind power projects. The relevant portion of
suggestion given by SECI is reproduced as under
connectivity in nearby CTU substations. During consultation with CTU,
it was known that many applications were received for same
substation and due to this constraint successful bidders under SECIs
scheme are not able to get connectivity. To continue with
developmental progress, role of Solar Energy Corporation of India Ltd
(SECI) is very important. Due to SECIs effort market has received
record low tariff for solar and wind power. Presently Renewable power
price is much below the conventional power price ................
Present regulation does not allow implementing agency to apply and
transfer connectivity right to other generator. It is requested to
Honourable Commission to allow SECI to take connectivity on behalf
of SPDs/WPDs for Stage-I connectivity and transfer the connectivity
right to successful bidder under SECIs scheme before Stage-II
application. .........
.... In continuation to that our humble submission is that SECI shall
submit application fee for connectivity for stage-l to CTU and BG if any
shall be submitted by generator after successful bidding and transfer
of connectivity right before stage-II application.
As per clause of 16.5 of connectivity regulation, CTU shall share the
available capacity of ISTS to bidding agency such as SECI. In that
case SECI may take the same information for bidding purpose.
According to the data, SECI may float the RfS based on substations
which will eliminate risk of mismatch between development of project
and connected substation/ transmission line.
Even before the bidding, SECI may file connectivity application as per
available data shared by CTU on behalf of Generator. Based on
approval from CTU, SECI may float bidding document. This will save
time and give certainty to generator for investment, resulting reduction
in tariff of renewable energy.
This will eliminate risk of blocking of bays in substations and bays
would be used effective way through SECIs tender.
Page 18
It is worthwhile to mention that DISCOMs shall express in buying
power on finalization of rates only, After finalization of buying utilities,
SECI shall share the information within 7 days to CTU for future
1.8. Considering the submissions of SECI, it is proposed that Central
Government nominated Implementing Agency will be eligible for grant of
Stage-I Connectivity and LTA on behalf of generators based on
renewable source(s) or Renewable Hybrid projects. The said
Implementing Agency or Designated Agency may apply for Stage I
Connectivity or LTA to the nodal agency as per the extant Connectivity
Regulations and detailed procedure issued therein.
10.3. Comments have been received from Greenko, MSEDCL, MPPMCL,
NTPC, POWERGRID and TANGEDCO:
10.3.1. Greenko has submitted that storage plants including pump storage hydro
plant will apply for connectivity for the quantum of maximum injection or
maximum drawal whichever is higher and sign separate agreement for both
injection and drawal.
10.3.2. MSEDCL Detailed Procedure for grant of
Connectivity to Projects based on Renewable Sources to inter-State
transmission system issued vide order dated 15.5.2018 also needs to be
amended to incorporate changes suggested in this draft regulation with
respect to applicant for connectivity for RE power station.
10.3.3. MPPMCL has suggested Project Developer should be defined in the
Regulations.
10.3.4. NTPC has submitted that in order to promote renewable and facilitate/widen
the ISTS Connectivity points, the Commission may consider allowing
aggregation of RE Capacity through generating switchyards of ISGS which
are already connected with ISTS. Accordingly, Generating Company,
authorised by Central government as 'Implementing Agency' may undertake
tariff based competitive bidding considering the ISGS switchyard as existing
connection point.
10.3.5. POWERGRID has suggested that since Renewable Power developers are
not known prior to bid, the provision should be modified to incorporate this.
10.4. Analysis and decision:
Page 19
10.4.1. NTPC has suggested to consider allowing aggregation of RE Capacity
through generating switchyards of ISGS which are already connected with
ISTS. The proposal of NTPC is outside the present scope of amendment.
The point has been noted.
10.4.2. We are in agreement with the suggestion of Greenko. Since, storage plant
may also draw electricity from the grid, we are of the view that the storage
plants shall apply for connectivity for the quantum of maximum injection or
maximum drawal whichever is higher and shall sign separate agreement for
both injection and drawal of power. A new Clause in this regard has been
added after existing Clause (1) of Regulation 8 of the Principal Regulations
as under:
(1A) A project based on standalone storage source(s)shall apply for
connectivity for the quantum of maximum injection or maximum drawal
whichever is higher and shall sign separate agreement for both injection and
drawal of power;
10.4.3. With regard to suggestion of MSEDCL for inclusion of changes proposed
for Projects based on Renewable Sources to Inter-State Transmission
, it is clarified that the Regulations will prevail over the detailed
procedure in case of any mismatch.The necessary changes shall be brought
out in detailed Procedure in due course of time.
10.4.4.
that words have been deleted in the amendment
10.4.5. With regard to suggestion of POWERGRID that Renewable Power
Developers are not known to RE Implementing Agency prior to bid, it is
clarified that Renewable Energy Implementing Agency shall apply for
Connectivity on behalf of the Renewable Energy Generating station(s).
10.4.6. In view of above discussion, the following two sub-clauses shall be added
after sub-clause (b)(i)(f) of clause (1) of Regulation 2 of the Principal
Regulations:
Page 20
State Government as Renewable Energy Implementing Agency on
behalf of the Renewable energy generating station(s)of the description
under Clause 2(1)(b)(i)(aa) and 2(1)(b)(i)(cc) or;
(h) Project based on standalone storage source(s) of installed capacity
11. Amendment in the definition of “Applicant” in respect of grant of Long-
term Access or Medium-term Open Access:
11.1. The sub-clause (b)(ii) and sub-clause (b)(iii) of Clause (1) of Regulation 2 of
the Principal Regulations was proposed to be substituted as under:
consumer, an electricity trader or a distribution licensee or applicant
covered under Clauses 2(1)(b)(i)(a) to (e) and 2(1)(b)(i)(h), in respect of
long-term access or medium-
11.2. The Commission had given following rationale while proposing the
above amendment:
1.11. The addition of certain new categories as applicants for
connectivity also necessitates amendment in the sub-clauses (ii) and
(iii) of clause (1) of Regulation 2 of the Connectivity Regulations.
11.3. No comments have been received from stakeholder on these Regulations.
11.4. Accordingly, sub-clause (b)(ii) and sub-clause (b)(iii) of Clause (1) of
Regulation 2 of the Principal Regulations shall be substituted as under:
consumer, an electricity trader or a distribution licensee or applicant
covered under Clauses 2(1)(b)(i)(a) to (e) and 2(1)(b)(i)(h), in respect of
long-term access or medium-
and Clause
12. Addition of new definitions:
12.1. The following provisions was proposed to be added after sub-clause
(k) of clause(1) of Regulation 2 of the Principal Regulations:
Page 21
-or entity designated by
the Central Government or the State Government for selection of
Renewable Power Developer and to act as Intermediary Procurer who
shall buy power from these developers and sell the same to one or
more distribution licensees in accordance with the Guidelines issued
from time to time by the Ministry of Power, Government of India or the
Ministry of New and Renewable Energy, Government of India or the
State Government.
12.1.1. The Commission had given following rationale while proposing the
above amendment:
MNRE for selection of developers based on tariff based competitive
bidding for implementation of grid connected Solar and Wind Scheme.
In line with SECI, the Central Government or the State Governments
selection of developers based on tariff based competitive bidding for
implementation of grid connected Solar and Wind Scheme. Therefore,
12.1.2. Comments have been received from GRIDCO, NTPC, POWERGRID and
SECI:
(a) GRIDCO has submitted that presently NLDC has been nominated as
Implementing Agency under the Sharing Regulations for calculation of
ISTS charges& losses, so another IA term will create confusion. They
have suggested that the Implementing Agency defined here may be
renamed as RE Implementing Agency cum Intermediary Procurer or
any other suitable name.
(b) NTPC has suggested that the definition of "Implementing Agency" may
include Bulk Power Procurers/ Power Traders in addition to Distribution
Licensees in order to provide more flexibility in the regulations.
(c) POWERGRID has suggested that SECI may tie up with beneficiaries
other than distribution licensees also such as bulk consumers in future.
(d) SECI has submitted that as per clause of 16.5 of
for Grant of Connectivity to projects based on renewable energy sources
to inter-State Transmission System, CTU shall share the available
capacity of ISTS to bidding agency such as SECI. In that case SECI may
Page 22
take the same information for bidding purpose. Before the bidding, SECI
shall file connectivity application as per available data shared by CTU on
behalf of Generator. Based on approval from CTU, SECI shall float
bidding document. This will save time and certainty to generator for
investment and which will also eliminate risk of mismatch between
development of project and connected substation/transmission line.
Further, SECIs tender comes under various magnitude i.e. 1000MW,
1200MW, 2000MW and 10,000MW, in which bidders are allowed to bid
for Min capacity of 50MW. In a typical 2000MW tender 5 to 6 bidders
were selected. Accordingly for a typical location SECI shall take Bulk
Stage-I connectivity and distribute the capacity amongst the successful
bidders based on LOI. SECI has requested that Government nominated
implementing agency should not be allowed to hold the connectivity
exceeding 9 months from date of Stage-1Connectivity and in case it
goes beyond the 9 months then said connectivity will stand cancelled.
12.1.3. Analysis and decision:
(a) We agree with suggestion of GRIDCO to rename
to avoid confusion with existing Implementing Agency defined under the
Sharing Regulations. Further, we also agree with suggestion of NTPC
and POWERGRID that enewable Energy
may also tieup with buyers other than distribution licensees as per
guidelines of Government. Accordingly, the definition has been modified.
(b) With regard to suggestion of SECI that the government nominated
implementing agency should not be allowed to hold the connectivity
exceeding 9 months from date of Stage-1 Connectivity and in case it
goes beyond the 9 months then said connectivity will stand cancelled, it
grant of Connectivity to Projects based on Renewable Source of Energy
sources to inter-State Transmission System (ISTS) vide order dated
-I Connectivity
grantee shall cease to be Stage-I Connectivity grantee if it fails to apply
for Stage-II Connectivity with 24 months from grant of Stage-I
Connectivity. The relevant portion of the said detailed procedure reads
as under:
Page 23
-I Connectivity grantees who fail to apply for Stage-II
Connectivity within 24 months from grant of Stage-I Connectivity shall
cease to be Stage-I grantee and their Application fees shall be for
Accordingly, the provision prescribed under the said detailed procedure shall
also be applicable in case of Stage-I Connectivity granted to SECI.
12.1.4. In view of above discussion, following provisions shall be added after sub-
clause (k) of clause(1) of Regulation 2 of the Principal Regulations:
-Renewable Energy
entity designated by the Central Government or the State Government
to act as Intermediary Procurer to select and buy power from
Renewable energy generating station(s) and sell the same to one or
more distribution licensees or any other person in accordance with the
Guidelines issued from time to time by the Ministry of Power,
Government of India or the Ministry of New and Renewable Energy,
Government of India or the State Government
12.2. The following provisions was proposed to be added after sub-clause (r)
of clause (1) of Regulation 2 of the Principal Regulations, namely:
"(r-
station based on any renewable source of energy, and shall include
Renewable Hybrid Generating Station
(r- generating
station based on hybrid of any renewable source(s) with or without
storage;
(r-
on hybrid of any renewable source(s) with or without storage;
(r-d
Developer or Wind Power Developer or Renewable Hybrid Power
Developer which shall be responsible for developing the Renewable
Energy Generating Station;
(r- mean a Solar Power
Park Developer or Wind Power Park Developer or Renewable Hybrid
12.2.1. The Commission had given following rationale while proposing the
above amendment:
Page 24
1.13. Further, projects based on renewable energy sources are getting
connected to the grid in large number. In future, the developers may
integrate storage with projects based on renewable energy sources to
reduce intermittency of RE generation. In order to bring clarity to
developers and to facilitate them in smooth integration with grid, some
12.2.2. No comments have been received from stakeholders on this regulation.
12.2.3. Since, Renewable Power Developer is same as the Renewable Energy
Generating Station, therefore, the proposed definition of Renewable Power
Developer at Regulation 2(1)(r-d) has been deleted. The following provisions
shall be added after sub-clause (r) of clause (1) of Regulation 2 of the
Principal Regulations:
"(r- mean a generating
station based on any renewable source of energy, and shall include
Renewable Hybrid Generating Station
(r-
station based on hybrid of any renewable source(s) with or without
storage;
(r-
on hybrid of any renewable source(s) with or without storage;
(r-d
Park Developer or Wind Power Park Developer or Renewable Hybrid
12.3. The following provision was proposed to be added after sub-clause (u)
of clause (1) of Regulation 2 of the Principal Regulations:
-
technologies like, Solid State Batteries, Flow Batteries, Pumped Storage
hydro-power, Compressed Air, or any other technology, to store various
12.3.1. Comments have been received from POWERGRID and SECI.
12.3.2. POWERGRID and SECI have suggested that the energy storage system
should not only store various form of energy but also discharge or deliver the
stored energy in the form of electricity.
Page 25
12.3.3. We agree with the suggestion of POWERGRID and SECI that the energy
stored in the storage devices will be ultimately be discharged in the form of
electricity to the grid.
12.3.4. In view of above discussion, following provision shall be added after sub-
clause (u) of clause (1) of Regulation 2 of the Principal Regulations:
- system utilizing methods and
technologies like, Solid State Batteries, Flow Batteries, Pumped
Storage hydro-power, Compressed Air, or any other technology, to
store various forms of energy and deliver the stored energy in the form
of electricity.
13. Amendment to Regulation 5 of the Principal Regulations:
13.1. The First proviso of Regulation 5 of the Principal Regulationswas proposed
to be substituted as under:
by any transmission lic
13.2. No comments have been received from the stakeholders on this Regulation.
Therefore, the clause is amended as proposed.
14. Amendment to 1
st
proviso to Regulation 8(1):
14.1. The First Proviso to Regulation 8 (1) was proposed to be substituted as
under:
Provided that where after filing of an application, there has been any
material change in the location of the applicant or change in the quantum
of power to be interchanged with the inter-state transmission system, by
more than 100 MW in the case of applicant defined under sub-clauses
(b)(i)(a) of Clause (1) of Regulation 2, 100 MW or 40% of the installed
capacity, whichever is less, in the case of applicant defined under sub-
clauses (b)(i)(aa), (b)(i)(b), and (b)(i)(h) of Clause (1) of Regulation 2
and 100MW or 40% of the aggregate installed capacity, whichever is
less, in the case of applicant defined under sub-clauses (b)(i)(c) and
(b)(i)(cc) of Clause (1) of Regulation 2, such an applicant shall make a
fresh application, which shall be considered in accordance with these
regulations
Page 26
14.2. Comments have been received from AGEL, InWEA, POWERGRID,
Greenko and TANGEDCO:
14.2.1. AGEL has submitted that a large wind farm spread over a larger area and
depending upon land allocated by the state revenue authorities, such wind
farm may be required to be established in different cluster. Therefore, the
same should not be considered as a material change in the location of the
applicant as long as the same wind farm is located in the same district of the
State and going to be connected at the same PGCIL/ Transmission
Licensee's sub-station where connectivity is granted. AGEL has requested to
modify the proposed regulation in line with regulation 7.14 in the draft CERC
(Grant of Connectivity and General Network Access to the inter-State
transmission system and other related matters) Regulations, 2017.
14.2.2. InWEA has submitted that Renewable Power Park developer is also an
eligible applicant and should have the same level playing field as the other
stake holders in revising the MW connectivity applied for.
14.2.3. POWERGRID has suggested that the applicants referred to at 2(1)(b)(i)(d),
2(1)(b)(i)(e), 2(1)(b)(i)(f) and 2(1)(b)(i)(g) should also be mentioned in the
this regulation.
14.2.4. Greenko has submitted that the proposed regulation may be modified to
include new provisions proposed for standalone storage and hybrid projects.
14.2.5. TANGEDCO has submitted that as per the proposed regulation 40% of
installed capacity for 50 MW implies that up to 30 MW there is no necessity
for filing fresh application which infers that 30 MW is adequate to process the
application and design the transmission system. This will lead to highly
uneconomical and inefficient ISTS system since the ISTS Pooling Stations
are either 765/400kV or 400/230kV substations. Hence the minimum
requirement for connectivity to ISTS should be 250 MW and above (pooled
capacity) to avoid creation of redundant capacity in the system.
14.3. Analysis and decision:
14.3.1. With regard to submission of AGEL to modify the instant provision in line
with Regulation 7.14 in the draft CERC (Grant of Connectivity and General
Network Access to the inter-State transmission system and other related
matters) Regulations, 2017 (Draft GNA Regulations), it is clarified that the
Commission is in the process of finalizing the Draft GNA Regulations and the
Page 27
suggestion given by AGEL shall be taken care while finalizing draft GNA
Regulations.
14.3.2. With regard to suggestion of Greenko, it is clarified that project based on
standalone storage sources and hybrid projects are already covered under
the proposed regulation.
14.3.3. We agree with the suggestion of InWEA that Renewable Power Park
Developer should also be an eligible applicant and the same has been
included in the Regulations.
14.3.4. We agree with suggestion of POWERGRID and the applicants referred to at
2(1)(b)(i)(d), 2(1)(b)(i)(f) shall be included in the instant provision. With
regard to applicant defined under Regulation 2(1)(b)(i)(e), it is clarified that
any revision in quantum shall be allowed only if it doesnot make the entity
ineligible for grant of Connectivity to ISTS.
14.3.5. With regard to submission of TANGEDCO, it is clarified that the minimum
quantum required for Connectivity to ISTS must be met at all times.
14.4. Based on above discussions, First Proviso to Regulation 8 (1) shall be
substituted as under:
Provided that where after filing of an application, there has been a
material change in the location or in the quantum of power to be
interchanged with the inter-state transmission system, by more than
100MW or 40% of the installed capacity, whichever is less, in the case
of applicant defined under sub-clauses (b)(i)(a),(b)(i)(aa), (b)(i)(b),
(b)(i)(d), (b)(i)(e), (b)(i)(f), (b)(i)(g)and (b)(i)(h) and 100MW or 40% of the
aggregate installed capacity, whichever is less, in the case of applicant
defined under sub-clauses (b)(i)(c) and (b)(i)(cc), of Clause (1) of
Regulation 2, such an applicant shall make a fresh application, which
shall be considered in accordance with these regulations
Provided further that such change in quantum of power to be
interchanged with inter-State transmission system shall be allowed only
if the applicant remains eligible under clause 2(1)(b).
15. Addition of new proviso after 1
st
proviso to Regulation 8(1):
15.1. A new proviso was proposed to be added after first proviso to clause (1) of
Regulation 8 of the Principal Regulations as under:
Page 28
Provided that an applicant connected with the grid or granted
connectivity for a specific project can, with prior approval of CTU, utilize
the same Connectivity for additional generation capacity (for same or
hybrid of renewable sources), subject to the condition that net injection
at any point of time does not exceed the quantum of total Connectivity
granted for the existing project. For such additional generation capacity,
existing generating station shall undertake all operational and
commercial responsibilities for the additional capacity in following the
provisions of the Indian Electricity Grid Code and all other regulations of
the Commission, such as grid security, scheduling and dispatch,
collection and payment/adjustment of Transmission charges, UI
charges, congestion and other charges etc., and submit an undertaking
in this regard to the CTU, with copy to the respective RLDC in whose
control area it is located
15.2. Comments have been received from AGEL, Greenko, MSEDCL,
POWERGRID, TANGEDCO and TERI:
15.2.1. AGEL has supported this amendment.
15.2.2. GRIDCO has suggested that the Regulation should clearly stipulate "What if
in case the net injection at any point of time does exceed the quantum of
total Connectivity granted for the existing project?"The associated financial
repercussions of such variation are to be clearly mentioned in the Regulation
& UI Charges should be replaced with deviation charges wherever it is
referred. The CERC (Deviation Settlement Mechanism and related matters)
(2
nd
amendment) Regulations, 2015 to be applicable for RE generators as
well.
15.2.3. Greenko has suggested some changes in the provision as under:
Provided that an applicant connected with the grid or granted
connectivity (Stage-I and Stage-II) for a specific configuration/
technology of the project can, with prior approval of CTU, utilize the
same Connectivity for different configuration/ technology or additional
generation capacity (like interchangeability between solar and wind or
between solar/ wind to hybrid of wind and solar with any type of
storage options/ standalone storage or standalone storage), subject to
the condition that net injection at any point of time does not exceed the
quantum of total Connectivity granted (Stage-I and Stage-II)earlier. For
such changes in the configuration or technology options or generation
capacity addition, applicant granted connectivity earlier shall undertake
all operational and commercial responsibilities for such changes in
following the provisions of the Indian Electricity Grid Code and all other
regulations of the Commission, such as grid security, scheduling and
dispatch, collection and payment/adjustment of Transmission charges,
UI charges, congestion and other charges etc., and submit an
Page 29
undertaking in this regard to the CTU, with copy to the respective RLDC
in whose control area it is located;
15.2.4. Greenko has further submitted that in case applicant applies for connectivity
with some configuration of Solar / wind or Hybrid of Solar & wind with any
type of storage and even if the application is in process, it can change its
configuration so long the quantum of power to be exchange with ISTS
remain same or change in quantum of power is maximum to 100MW or 40%
of earlier applied connectivity (whichever is less). Greenko has also
submitted that hybrid generation projects may apply for connectivity and LTA
as per its commercial and technical agreement subject to condition that
transaction of power should not be more than the quantum of connectivity
granted.
15.2.5. MSEDCL has suggested that permission may be granted to use connectivity
for RE generator for same or hybrid type of RE generation; provided there is
no change in approved connectivity quantum. However permission to utilise
existing connectivity for additional generation capacity shall not be allowed.
This is because there is no mechanism by which it would be monitored that
net injection at any point of time does not exceed the quantum of total
connectivity. There is possibility of misuse of this facility by RE generators.
Also there is no provision to restrict RE generator from injecting more power
into grid than approved. This will affect system security of grid. There is no
provision of penalty for exceeding approved injection, as RTDA charges are
not applicable for RE generator with solar or wind as per the Sharing
Regulations. Further, the generator may take connectivity for lesser quantum
and inject more power into grid. This may lead to further network congestion
as evacuation system would be designed considering connectivity & LTA.
15.2.6. POWERGRID has suggested some modification in the proposed
amendment and sought clarification ional generation
the .
15.2.7. TERI has submitted that the words 'UI charges' may be substituted with
'charges for deviation'. Further, the Regulation may also address the
situation where net injection exceeds the quantum of total connectivity.
15.2.8. TANGEDCO has submitted that the second proviso should be subject to
point of injection and drawal remaining the same and does not require any
Page 30
system augmentation. Further, the principle generators shall also undertake
the commercial responsibilities and the CERC (Deviation Settlement
Mechanism and related matters) (Second Amendment) Regulations, 2015 to
be followed by the RE Generators.
15.3. Analysis and decision:
15.3.1. With regard to suggestion of Greenko for change in configuration or
technology of the project during the period of processing of the application
for grant of Connectivity or after Connectivity has been granted, , the
applicant shall intimate the same to CTU and CTU shall process the
application for grant of Connectivity accordingly.
15.3.2. GRIDCO ,TERI and MSEDCL have sought clarification of treatment of
condition when the net injection at any point of time does exceed the
quantum of total Connectivity granted for the existing project and associated
financial repercussion of such variation. In this regard it is clarified that
injection more than the quantum of granted Connectivity shall not be
allowed. For the event that an entity resorts to over injection over and above
quantum of Connectivity, Commission may come out with separate
framework under CERC DSM Regulations..Further, in order to alleviate the
concern of stakeholders regarding misuse of this provision by RE
generators, we direct POSOCO to monitor injection by such applicants
covered under this provision and file quarterly exception report to the
Commission.
15.3.3. We agree with changes proposed by POWERGRID in the provision. Further,
POWERGRID has sought clarification
the applica
regard it is clarified that the additional generation capacity
proposed amendment shall refer to the applicant own generation
15.3.4. With regard to suggestion of TANGEDCO that the proposed amendment
should be subject to point of injection and drawal remaining the same and
does not require any system augmentation, it is clarified that injection point
of generators granted connectivity under this provision shall remain same
but the drawal point may vary as the additional generation capacity may
have PPA with different entities. Further, since Connectivity quantum
Page 31
remains same, no transmission system augmentation shall be carried out for
grant of Connectivity, We also agree with suggestion of TANGEDCO that the
existing generating station shall undertake the commercial responsibilities
and the CERC (Deviation Settlement Mechanism and related matters)
(2
nd
Amendment) Regulations, 2015 and the same has already been
proposed in the regulation.
15.3.5. We
15.3.6. We observe that an applicant approaching CTU under the instant Clause
should also be liable to pay application fees for Connectivity based on
additional installed capacity. Accordingly regulations have been amended to
include this provision.
15.4. Based on above discussions, a new proviso shall be added after first
proviso to clause (1) of Regulation 8 of the Principal Regulations as
under:
Provided that an applicant connected with the grid or granted
connectivity for a specific project can, with prior approval of CTU, utilize
the same Connectivity for additional generation capacity (for same or
hybrid of renewable sources), subject to the condition that net injection
at any point of time does not exceed the quantum of total Connectivity
granted for the original project. For such additional generation capacity,
the said generating station shall undertake all operational and
commercial responsibilities for the additional capacity for compliance of
the provisions of the Indian Electricity Grid Code and all other
regulations of the Commission, such as grid security, scheduling and
dispatch, collection and payment/adjustment of Transmission charges,
charges for deviation, congestion and other charges etc., and submit an
undertaking in the prescribed format in this regard to the CTU, with
copy to the respective RLDC in whose control area it is located. The
applicant shall make an application to CTU for Connectivity for
additional capacity and pay the application fee as specified in
Regulation 6 of these Regulations
16. 2
nd
proviso to Regulation 8(1) (3rd proviso as per the proposed
amendment):
16.1. In the existing 2
nd
proviso to Regulation 8(1) (3rd proviso as per the proposed
was proposed to be
Page 32
16.2. Comments have been received from Greenko and InWEA.
16.2.1. Greenko has submitted that the agreement among generators should be in
place before grant of physical connectivity.
16.2.2. InWEA has submitted that Renewable Power Park Developer is on par with
a generating company and hence need be included for consideration of Lead
Generator.
16.3. Analysis and decision:
16.4. nko. We are of the view that the
applicant defined under Regulation 2(1)(b)(i)(c) and Regulation 2(1)(b)(i)(cc)
shall have to formalize a written agreement among themselves before
application for grant of Connectivity.
16.5. InWEA as the role of Renewable Power
Park Developer may be different from that of a generating company and
hence, Renewable Power Park Developer cannot be included for
consideration of Lead Generator. Further, the Regulations allow only
government authorized park developers, the requirement of Lead Generator
will not arise.
16.6. In view of above discussion, in the existing 2
nd
proviso to Regulation 8(1) (3rd
proviso as per the
shall be added after the
.
17. Fourth Proviso (5
th
proviso as per the proposed amendment) to
Regulation 8 (1):
17.1. The existing Fourth Proviso (5
th
proviso as per the proposed amendment) to
Regulation 8 (1) was proposed to be substituted as under:
Provided also that the Renewable Power Park Developer is authorised
by the Central or State Government to undertake infrastructural
activities including arrangement for connectivity on behalf of the
Renewable power generators
17.2. Comments have been received from InWEA and Greenko.
Page 33
17.2.1. InWEA has submitted that in order to give more clarity the relevant reference
to regulation should be inserted after the word "Renewable power park
developer".
17.2.2. Greenko has submitted that standalone Storage Developer should also be
added in the amendment.
17.3. Analysis and decision:
17.3.1. Renewable
Power Park Developer2(1)(b)(i)(f) and it is
not necessary to include a reference for the same.
17.3.2. The suggestion of Greenko is outside the scope of present amendment.
17.4. Based on above discussions, the existing Fourth Proviso (5
th
proviso
as per the proposed amendment) to Regulation 8 (1) shall be
substituted as under:
Provided also that the Renewable Power Park Developer is authorised
by the Central or State Government to undertake infrastructural activities
including arrangement for connectivity on behalf of the Renewable power
generators;
18. Addition of new clause after Clause (2) of regulation 8 of the Principal
Regulations:
18.1. The following clauses were proposed to be added after Clause (2) of
regulation 8 of the Principal Regulations:
Applications for grant of Connectivity made by applicants covered
under sub-clauses (aa), (cc), (e), (f), (g) and (h) of Clause (1)(b)(i) of
Regulation 2shall be processed in two stages:
(a) Stage-I Connectivity
(b) Stage-II Connectivity
(2B) Grant of Stage-I and Stage-II Connectivity shall be as per the
Detailed Procedure issued from time to time.
Provided that the Detailed Procedure for grant of Connectivity to
Projects based on renewable Sources to inter-State transmission system
issued vide order dated 15.5.2018 in File No. L-1/(3)/2009-CERC shall
be deemed to have been issued under these Regulations.
(2C) In case of applicants covered under sub-clause (b)(i)(g) of clause
(1) of Regulation 2, the connectivity granted to such applicants may be
Page 34
transferred or assigned, in part or full, in favour of the Renewable Power
Developers selected by the said applicants after award of the project. On
transfer or assignment of connectivity, such developers shall enter into
Connectivity Agreement with CTU and accept all responsibilities and
liabilities for connectivity as required under these Regulations and
Detailed Procedure
18.2. Comments have been received from AGEL, IL&FS, POWERGRID and
TANGEDCO:
18.2.1. AGEL and IL&FS have submitted that
Procedure for grant of Connectivity to projects based on renewable energy
sources to inter-State Transmission System sets out various milestones to
be achieved by the 'Applicant' before applying for grant of Stage-II
Connectivity. However, in case of a Solar/Wind/Hybrid Power Park
Developer, achieving financial closure or release of 10% funds towards
generation project milestones is not possible without identification of the RE
Project Developer for setting up of generating station in the park. They have
requested for suitable amendment in the detailed procedure for exemption of
Renewable Power Park Developer from prerequisites for grant of Stage-II
Connectivity.
18.2.2. IL&FS has also submitted that CTU should also provide a time frame as on
when the connectivity would be completed from the date of application of
Stage-II Connectivity. Such indicative time frame would enable the RE
project developers and RE park developers to estimate risk associated with
the connectivity and accordingly take actions to mitigate the same.
18.2.3. POWERGRID has submitted that connectivity for applicant under Clause
2(1)(b)(i)(e) is to be granted at the existing connection point, requirement of
separate stage-II connectivity may not be there. Further, in case of Clause
2(1)b(i)(g) stage-II connectivity is not required as per Clause 12(1)(A).
Accordingly, connectivity is to be granted as Stage-II Connectivity with firm
location to facilitate application for LTA. However, Connectivity BG and
Connectivity agreement shall be required under stage-II connectivity for both
the above cases. POWERGRID has further submitted that in case of transfer
or assignment of connectivity granted to applicant covered under sub-clause
(b)(i)(g) of clause (1) of Regulation 2, such Applicant shall be liable for all
Page 35
regulatory, operational and commercial obligations of a connectivity grantee
up to such transfer or assignment. Also, upon transfer or assignment, the
transferee Renewable Power Developer shall be liable for all regulatory and
commercial obligations of a connectivity grantee for the quantum of
connectivity so transferred or assigned.
18.2.4. TANGEDCO has submitted that an additional clause should be added after
Regulation 8(2C) providing that the Stage-II connectivity applicant will enter
into an indemnifying agreement with CTU upon grant of Stage II connectivity.
CTU shall process the implementation of the transmission scheme only after
indemnification between CTU and the developer of RE project is signed to
recover the transmission charges for the assets created on account of the
RE generator in case of non-firming up of generation project or end
beneficiaries.
18.3. Analysis and decision:
18.3.1. With regards to AEGL and IL&FS submissions regarding achieving financial
closure or release of 10% funds for generation project milestones,it is
clarified that in case of Power Park Developers, release of 10% fund shall be
equal to 10% of the cost towards Power Park which may be funds released
for land or any other activity associated with the park, and does not
necessarily mean the 10% toward cost of generation projects to be
established in the Power Park.
18.3.2. With regards to IL&FS submissions to clearly provide timeframe by which
Connectivity shall be assured by CTU, it is clarified that CTU shall provide a
firm date when it will provide Connectivity to the applicant. In case of default,
the mechanism are built in the Regulations.
18.3.3. We agree with POWERGRID suggestion that applicant under Clause
2(1)(b)(i)(e) shall not apply for stage-II connectivity separately since it shall
be connected through electrical system of existing generating station. It shall
apply for Connectivity under extant Regulations and shall not fall under
detailed Procedure dated 15.5.2018.We donot find any requirement for
Connectivity BG as per Procedure dated 15.5.2018 in these cases. However
Stage-II Connectivity for applicants under Regulation 2(1)(b)(i)(g). In respect
of applicant defined under Regulation 2(1)b(i)(g),Stage-II Connectivity shall
Page 36
be required. Keeping in view other proposals of POWERGRID we have
incorporated the changes as suggested. We also observe that applicant
under Regulation 2(1)b(i)(g) may also seek LTA and may need to transfer
the same to Renewable Energy Generating station. Accordingly same has
been added in the Clause.
18.3.4. With regard to suggestion of TANGEDCO for addition of an additional
provision regarding signing of indemnification agreement between CTU and
Stage-II Connectivity grantee to recover cost of transmission system
implemented for them in case of non-firming of beneficiaries, it is clarified
that the concern of TANGEDCO has already been addressed by the
Commission vide the Statement of Reasons to the CERC (Grant of
Connectivity, Long-term Access and medium-term Open Access in inter-
state Transmission and related matters) (5
th
Amendment) Regulations, 2015,
and CERC (Grant of Regulatory Approval for execution of Inter-State
Transmission Scheme to Central Transmission Utility) (1
st
Amendment)
Regulations, 2015 that transmission charges for delay in commissioning of
solar power generators are required to be paid by such solar
generators/SPPD on the same line as the liability for payment by the thermal
and hydro generating stations in accordance with the Central Electricity
Regulatory Commission (Terms and Conditions of Tariff) Regulations, 2014.
The relevant portion of the Statement of Reasons is extracted as under:
shall apply for Connectivity/Long term Access shall be liable to deposit
Application Bank Guarantee/Construction Bank Guarantee as required under
Connectivity Regulation. Further, SPPD shall also be liable for payment of
transmission charges for delay in commissioning of generator and
relinquishment charges towards transmission access under Connectivity
Regulations and Sharing Regulations. Regulation 7(1)(u) of the Sharing
Regulations provides that "No transmission charges for the use of ISTS
network shall be charged to solar based generation" is applicable only when
the power is evacuated through the transmission system to the beneficiaries
after the commercial operation of the generating station. Therefore,
transmission charges for delay in commissioning of solar power generators
shall be payable by such solar generators/SPPD on the same line as the
liability for payment by the thermal and hydro generating station in accordance
with the Central Electricity Regulatory Commission (Terms and Conditions of
Tariff) Regulations, 2014.
Page 37
8.2.2 With regard to delay of internal system, it is clarified that SPPD shall be
executing internal system on behalf of solar power generators. The treatment
of delay or other modalities should be covered in Agreement between solar
power generators and SPPD. In regard to NTPC's comments on development
of transmission matching with generation, it is clarified that CTU shall carry out
coordination with the SPPD/solar power generators in accordance with
18.4. Based on above discussions, the following clauses shall be added
after Clause (2) of regulation 8 of the Principal Regulations:
applicants covered
under sub-clauses (aa), (cc), (f), (g) and (h) of Clause (1)(b)(i) of
Regulation shall be processed in two stages:
(a) Stage-I Connectivity
(b) Stage-II Connectivity
(2B) Grant of Stage-I and Stage-II Connectivity shall be as per the
Detailed Procedure issued from time to time.
Provided that the Detailed Procedure for grant of Connectivity to Projects
based on renewable Sources to inter-State transmission system issued
vide order dated 15.5.2018 in File No. L-1/(3)/2009-CERC shall be
deemed to have been issued under these Regulations.
(2C) In case of an applicant covered under sub-clause (b)(i)(g) of clause
(1) of Regulation 2, the connectivity and LTA granted to such an applicant
may be transferred or assigned, in part or full, in favour of the Renewable
Energy Generating Station(s) selected by the said applicants after award
of the project. On transfer or assignment of connectivity and LTA, such
Renewable Energy Generating Station(s) shall enter into Connectivity and
LTA Agreement with CTU and accept all responsibilities and liabilities for
connectivity as required under these Regulations and Detailed Procedure;
Provided that up to such transfer or assignment, such Applicant shall be
liable for all regulatory, operational and commercial obligations of a
connectivity and LTA grantee;
Provided further that upon transfer or assignment, the transferee Renewable
Energy Generating Station(s)shall be liable for all regulatory and commercial
obligations of a connectivity and LTA grantee for the quantum of connectivity
and LTA so transferred or assigned.
Page 38
19. Amendment in Regulation 8(3) and addition of a new clause after
clause 3 of Regulation 8 of the Principal Regulations:
19.1. except applicants indicated
in Clause 3A below was proposed to be added While
granting connectivity, the nodal agency shall specify the name of the sub-
station or pooling station or switchyard where connectivity is to be granted
19.2. The following new sub-clauses was proposed to be added after Clause
(3) of Regulation 8 of the Principal Regulations:
(3A) For applicants covered under sub-clauses,(aa), (cc), (e), (f), (g) and
(h) of clause (1)(b)(i) of Regulation 2, CTU shall grant Stage-I
Connectivity by indicating two locations - one Primary and other alternate
location
19.3. Comments have been received from Greenko and TANGEDCO:
19.3.1. Greenko has queried as to whether the proposal shall include Renewable
Power Park Developer and Standalone Storage Developer. Further, with
based on Renewable Source of Energy to Inter-State Transmission Sys
in case some developer get eligible for stage 2 either by winning a bid from
central/state agency or get eligible by purchasing the land and capex
inclusion, will there be timeline to be given by CTU to ensure connectivity.
This aspect is very important particularly looking into the provision that after
grant of stage 2 connectivity, the applicant need to develop pooling station
and connectivity line in 24 months and also the developer has deposited BG.
.Under this situation CTU need to ensure that there is availability of grid
station to get connected.
19.3.2. TANGEDCO has submitted that the alternate location should be mentioned
as "subject to the primary location becomes infeasible
19.4. Analysis and decision:
19.4.1. With regard to Greenko submission, it is clarified that the timeline for
implementation of transmission system shall be provided to the grantee by
CTU..
Page 39
19.4.2. With regard to suggestion of TANGEDCO that the alternate location should
be mentioned as "subject to the primary location becomes infeasible
clarified that we have done away with identification of two locations. We
observe that in case an Applicant does not apply for Stage-II Connectivity
within 24 months of Stage-I Connectivity, its Stage-I Connectivity shall be
cancelled as per detailed Procedure.
19.4.3. We observe that provision of alternate location was kept in the detailed
procedure dated 15.5.2018 to indicate that a situation may arise that
capacity at the location gets fully allocated and few grantees have to be
allocated a new location. To make things clear, we have included a provision
in the instant amendment that CTU shall grant Stage-I Connectivity
indicating only one location. It may happen that such a location has capacity
of 5000 MW but CTU gets applications for 10000 MW. CTU shall grant
Stage-I Connectivity to all such applicants at the same location. Out of this
10000 MW applicants, first 5000 MW who becomes eligible for Stage-II will
get confirmed at the location as per detailed procedure. Such additional
Stage-I grantees who becomes eligible for Stage-II Connectivity shall be
confirmed Stage-II Connectivity at alternate location. In case such Stage-I
grantees have also been granted LTA, modified LTA grant shall be issued by
CTU from alternate location. In case of any conflict between detailed
procedure and Regulations, provisions of regulation shall prevail. The
necessary changes shall be brought out in detailed Procedure in due course
of time.
19.4.4. Based on above conclusion no change shall be done in existing Clause3 of
Regulation 8.
19.5. Based on above discussions, following new sub-clauses shall be
added after Clause (3) of Regulation 8 of the Principal Regulations:
contrary in any other Regulations
or the Procedure applicants covered under sub-clauses,(aa), (cc), (f), (g) and
(h) of clause (1)(b)(i) of Regulation 2 shall be grant Stage-I Connectivity by
CTU by indicating one location and such other information as required under
Clause (3) of this Regulation:
Page 40
Provided that if the capacity in the said location is fully allocated to Stage-II
grantees, the balance Stage-I grantees shall be allocated Stage-II
20. First Proviso to Clause (8) of Regulation 8:
20.1. The First Proviso to Clause (8) of Regulation 8 of the Principal Regulations
was proposed to be substituted as under:
above or a hydro generating station or a renewable energy generating
station or a project based on standalone storage source(s) of capacity of
250 MW and above, CTU shall plan the system such that maximum
length of dedicated transmission line does not exceed 100 km from
switchyard of the generating station till the nearest pooling substation of
transmission licensee
20.2. Comments have been received from Greenko, SECI and TANGEDCO:
20.2.1. Greenko has submitted that the time required for setting up RE generating
station is less compared to make new pooling within 100 km. In case, there
is no sub-station within 100km, under this situation applicant should have a
choice to make dedicated line beyond 100 km also.
20.2.2. SECI has requested for amendment in the Connectivity Regulations to
enable setting up of Dedicated Transmission Line of length more than
100km by the project developer/entities other than CTU.
20.2.3. TANGEDCO has submitted that this provision is against the mandate of the
Electricity Act, 2003 under Sections 9 and 10. Hence, the dedicated
transmission lines shall be under the purview of the generator irrespective of
nature of the source. Hence, this proviso shall be modified in such a way to
recover the cost of the dedicated lines from the concerned generators.
Further, the bays for the dedicated lines at ISTS substation shall also be
built, operated and maintained by the generators.
20.3. Analysis and decision:
20.3.1. We have considered the comments of stakeholders.
20.3.2. Keeping in view suggestions of Greenko and SECI, a new proviso has been
added after 1st proviso to Regulation 8(8) of the Principal Regulations.
Page 41
20.3.3. With regard to submission of TANGEDCO the cost of dedicated line should
be recovered from the concerned generators, it is clarified that provision
regarding recovery of charges for dedicated line is already in force since
17.2.2017 vide 6
th
amendment to the Connectivity Regulations. Further,
regarding, construction of bays by the generators for the dedicated lines at
ISTS substation, we are of the view that the bays for termination of
dedicated transmission line should be constructed by the concerned
generating station to avoid mismatch between commissioning of dedicated
transmission line and associated bay at ISTS sub-station. However, the
detailed procedure approved vide order dated 15.5.2018 in context of
renewables provides as under.
“5.3 Scope of bays for dedicated transmission line
5.3.1 For the connectivity system, the dedicated transmission line including
line bays at generation pooling station shall be under the scope of the
applicant and the terminal bays at the ISTS sub-station shall be under the
scope of transmission licensee owning the ISTS sub-station subject to
compliance of relevant provision of tariff policy.
5.3.2 Wind power developers who have emerged successful in the bidding
conducted by Central/State Government designated agency, before coming
into force of this Procedure, shall have the option to implement the bays
associated with their dedicated lines at the ISTS sub-station by themselves or
through the transmission licensee owning the sub-station subject to
compliance of relevant provisions of tariff policy. The transmission licensee
and the project developer shall endeavour to match the implementation of
bays with that of associated dedicated transmission line
We observe that bay at ISTS substation associated with dedicated line
should be made by the Applicant itself. However a provision was made in
detailed procedure for Renewables issued vide Order dated 15.5.2018 that
such bays shall be under the scope of transmission licensee owning the
ISTS sub-station. This was introduced keeping in view that a situation may
arise that applicant doesnot construct its dedicated line or generating units
and the allocated bay is not getting utilized. In such a case CTU shall
allocate the bay to other Applicants. Such reallocation may be dispute free
and easier, if the bay is under the scope of ISTS licensee.
Page 42
However keeping in view the comments, we direct that in said cases for
renewables covered under detailed procedure dated 15.5.2018, Applicant
may enter into an agreement with CTU to construct the bay associated with
dedicated line at ISTS substation by itself. However if it doesnot utilize the
bay, CTU may cancel its Connectivity as per provisions of detailed
procedure and reallocate the bay to new applicant. In such a case, the
equipments installed by the grantee have to be dismantled by the grantee
within a period of 2 months cancellation of Connectivity or may be utilized by
the new grantee as per Agreement between outgoing grantee and new
grantee.
20.4. Further to above changes minor changes are required in the main Clause 8
of Regulation 8 to clarify that dedicated line may be constructed by
generating station of the applicant generating Company or any other entity
on behalf of generating company such as Renewable Power Park Developer
or Renewable Energy Implementation agency who are otherwise eligible
applicant.
20.5. Based on above discussions, Clause (8) of Regulation 8 of the Principal
Regulations shall be substituted as under:
The dedicated transmission line from generating station of the applicant
generating Company or any other entity on behalf of generating company
to the pooling station of the transmission licensee (including deemed
transmission licensee) shall be developed, owned and operated by the
applicant generating Company or any other entity on behalf of generating
company. The specifications for dedicated transmission lines may be
indicated by CTU while granting Connectivity or Long term Access or
Medium term Open Access:
Provided that CTU shall plan the system such that maximum length of
dedicated transmission line does not exceed 100 km from switchyard of
the applicant till the nearest pooling substation of transmission licensee.
Provided further that dedicated transmission line may exceed 100 km, if
such an Applicant, so chooses.
Provided also that in case any connectivity grantee is not utilizing the bay
allocated to it at ISTS substation, CTU may cancel its Connectivity as per
provisions of these regulations and detailed procedure and allocate the bay
to other Applicants. In such an event, the original grantee shall either
dismantle its bay or enter into an Agreement with a new grantee as indicated
by CTU for utilization of the bay within a period of 2 months of cancellation of
Connectivity.
Page 43
21. Addition of a new Regulation after Regulation 8 of the Principal
Regulations:
21.1. A new Regulation 8(A)was proposed to be added after Regulation 8 of the
Principal Regulations as under:
“8A. Transfer of Connectivity and LTA
A person shall not transfer, assign or pledge its connectivity or LTA and
the associated rights and obligations to any other person.
Provided that the above provision shall not be applicable to applicants
defined under Regulation 2(1)(b)(i)(g).
Provided further that 100% subsidiary companies shall be allowed to
21.2. The Commission had given following rationale while proposing the
above amendment:
3.1. The Commission vide order dated 29.9.2017 in Petition No.
145/MP/2017 inter alia observed as under:
120. The Commission has considered this issue. Though there is no
provision for transfer of connectivity to any other entity, RfS issued by
SECI allows creation of SPVs for project implementation. The
Respondents have submitted that such SPVs face difficulties in
implementation of their projects since they cannot utilize the
connectivity granted to their parent companies.
........
122. Keeping in view the fact that creation of SPV is an option under
RfS issued by SECI and that a number of companies are executing
the projects through creation of 100% subsidiaries after winning the
bids, we are of the view that the 100% subsidiary companies should
be allowed to utilize the connectivity granted to the parent
3.2. In view of the above, it is hereby clarified that a person who has
been granted Connectivity or LTA shall not transfer, assign or pledge its
connectivity or LTA and the associated rights and obligations to any
other person. Only, the 100% subsidiary companies shall be allowed to
utilize the connectivity granted to the parent company and vice versa.
However, the applicants covered under the sub-clause (b)(i)(g) of Clause
(1) of Regulation 2, i.e., the central Government or the State
Governments authorized implementing agency can transfer the
Connectivity and LTA granted to them as they have been permitted to
take LTA on behalf of the Renewable Power Developers
Page 44
21.3. Comments have been received from Adani Green Energy Ltd.
(AGEL), Greenko, Indian Wind Energy Association (InWEA), Inox
Wind Infrastructure Services Ltd (IWISL),MPPMCL, National Solar
Energy Federation of India (NSEEFI) and POWERGRID.
21.3.1. AGEL has suggested that if LTA has not yet been taken by the parent
company and 100% subsidiary companies are utilizing parent's
connectivity, the parent company shall apply for LTA on behalf of its 100%
subsidiary companies and vice versa.
21.3.2. Greenko has suggested that in case pooling station and dedicated
transmission line has capacity to accommodate more power transfer/
connectivity space, this can be allocated to new applicant by CTU. The
new applicant shall pay proportional transmission charges to the first
applicant who developed the dedicated line and pooling station. This
sharing of transmission charges will be considering the benchmark of the
cost determined by CERC for different components of such dedicated
system.
21.3.3. InWEA has suggested that transfer of Connectivity should also be allowed
in case of applicant defined under Regulation 2(1)(b)(i)(f) provided that it
undertakes such activities under the supervision of the transfer or.
Further, transfer of connectivity is possible even now in state sector from
renewable power park developer to several individual owners and the
same needs to be extended to central sector with control as suggested.
21.3.4. IWISL has submitted that there appears to be mismatch between the
language as envisaged under the proposed regulation and under
approved rocedure for grant of Connectivity to Generation
Projects based on Renewable Sources of Energy to Inter-State
and the same may be clarified or removed to synch
both. Further, there is no such risk of connectivity trading with the
enforcement of the aforesaid procedure as to apply for Stage-II
Connectivity one must have to achieve the milestone mentioned therein.
IWISL has also submitted the payers made by it in petition no.
29/MP/2018 as under:
(a) Direct the Respondent No.1 to allow the Petitioner to utilize the
connectivity granted to the Petitioner by its fully owned SPVs for
Page 45
execution of the projects awarded through the competitive bidding
carried out by SECI, only subject to the terms and conditions
stipulated in RFS issued by SECI and/or the subsequent Agreements/
Contracts entered into between the Petitioner and the Respondents
governing the controlling shareholding of the Petitioner and its SPVs.
(b) Direct that the directions contained in paragraph 122 of the order
dated 29.09.2017 passed by this Commission in Petition No.
145/MP/2017 as also the order dated 31.10.2017 passed by this
Commission in Petition No. 173/MP/2017, in so far as they are
inconsistent with the terms and conditions of the RFS issued by
Respondent No.1, shall not be applicable to the Petitioner and the
Petitioner shall be governed by the terms and conditions of the RFS
issued by Respondent No.1.
21.3.5. MPPMCL has suggested deleting the proposed 2nd proviso as the
subsidiary companies are separate legal entities than parent company.
21.3.6. NSEFI and AGEL have submitted that the Commission has provided that
"....sale of shares in the subsidiary company(ies) shall be allowed only
after one year of the commencement of supply of power from the SPV".
Further, by limiting only to "utilization", the parent and 100% subsidiary
relationship needs to remain forever. This situation would not be in line
with Bidding Documents as well as the Order and Procedures. Even the
RfS only provides for 51% shareholding lock-in i.e. 49% is allowed to be
transferred any time after signing of PPA. Thus to make it in line with RfS
document, condition should be made subsidiary/parent relationship and
not 100% subsidiary/parent relationship.
21.3.7. POWERGRID has suggested that A
person shall not transfer, assign or pledge its connectivity or LTA, in full or
in part and the associated rights and obligations to any other person.
21.4. Analysis and decision:
21.4.1. We agree with suggestion of AGEL that if LTA has not yet been taken by
the parent company and 100% subsidiary companies utilizing parent's
connectivity, the parent company shall apply for LTA and its 100%
subsidiary company(ies) may utilize the same and vice versa. We would
like to clarify that LTA can either be applied by an entity holding the
Connectivity or has applied for Connectivity. Further, the 100% subsidiary
Page 46
companies shall be allowed to utilize the connectivity or LTA granted to
the parent company and vice versa.
21.4.2.
covered in detailed procedure dated 15.5.2018.
21.4.3. We donot agree with suggestion of InWEA to allow transfer of
Connectivity granted to applicant defined under Regulation 2(1)(b)(i)(f)
i.e., entity or company authorized by the Central Government or State
Government as Renewable Power Park Developer,. The Renewable
Power Park Developers develop transmission network within the park to
collect power from each project and transmitting it to the transmission
sub-station of ISTS, provide transmission facility to allow connection of
individual projects with pooling stations. Hence, entity or company
authorized by the Central Government or State Government as
to individual generators..
21.4.4. Regarding submission of IWISL that there is some mismatch between the
proposed regulations and the detailed procedure for grant of connectivity
to RE projects, it is clarified that in case of mismatch, the Regulations will
prevail over the detailed procedure. Further detailed procedure shall be
amended in due course. With regard to the concerns raised by IWISL in
Petition no. 29/MP/18 in respect of requirement of RFS vis a vis the
provisions of regulations and detailed procedure it is clarified that sale of
shareholding have been covered in detailed procedure approved by the
Commission vide order dated 15.5.2018as under:
“5.2 Utilisation of Connectivity granted to the Parent Company by its
Subsidiary company (ies)
5.2.1 The Connectivity granted to a company may be utilised by its wholly
owned (100%) subsidiary company(ies) including SPVs. In such cases, the
parent company cannot sell its shareholding in the subsidiary company
(ies) before the lock-in period of one year after the commencement of
supply of power from such subsidiary.
In case of more than one wholly owned (100%) subsidiary of the
same company, the lock-in period of one year shall apply from
commencement of supply of power from the last such subsidiary. An
illustration is given below:
bid for 250 MW. It forms five wholly owned (100%) subsidiaries
of 50 MW each. In such a case lock-in period shall be 1 year
Page 47
from commencement of supply from last subsidiary (i.e.
5.2.2 In the cases covered under clause 5.2.1, the parent company will act
as lead generator and undertake all operational and commercial
responsibilities for the renewable energy generating station(s) in following
the provisions of the Indian Electricity Grid Code and other regulations of
the Commission, related to grid security, scheduling and dispatch,
collection and payment/adjustment of Transmission charges, deviation
charges, congestion and other charges etc. The consortium agreement
amongst lead generator and other generators shall be as per FORMAT
CON LGN.
21.4.5. Keeping in view MPPMCL suggestion that subsidiary companies are
separate legal entities we have modified the Clause to allow transfer of
Connectivity to Subsidiary after the specified lock-in period.
21.4.6. We agree with the suggestion of POWERGRID and regulation has been
full or parts.
21.4.7. With regard to suggestion of NSEFI and AGEL suggestion, it is clarified
that 100% subsidiary companies are allowed to utilize the Connectivity
granted to the parent company and vice-versa. Regarding shareholding
pattern in the subsidiary companies, Clause 5.2.1 of the Detailed
Procedure dated 15.5.2018 provides that the parent company cannot sell
its shareholding in the subsidiary company(ies) before the lock-in period
of one year after the commencement of supply of power from such
subsidiary (last subsidiary in case of more than one subsidiaries).
Further, to take care of comments of NSEFI and AGEL, transfer of
connectivity and LTA has been allowed.
21.5. Based on above discussions, a new Regulation 8(A)shall be added after
Regulation 8 of the Principal Regulations as under:
“8A. Transfer of Connectivity and LTA
A person shall not transfer, assign or pledge its connectivity or LTA
either in full or parts and the associated rights and obligations to any
other person.
Provided that the above provision shall not be applicable to applicants
defined under Regulation 2(1)(b)(i)(g).
Page 48
Provided further that 100% subsidiary companies shall be allowed to
transfer their connectivity and LTA to the parent company and vice
versa one year after achieving commercial operation of Renewable
Energy generating station(s):
Provided further that transfer of Connectivity and LTA from the parent
company to more than one 100% subsidiary shall be permitted one year
after the commercial operation of the generating station of the last
subsidiary and subject to minimum capacity as per Regulation 2(1)(b):
Provided also that till such Connectivity and LTA are transferred, the
concerned subsidiary company(ies) shall be allowed to utilize the
22. Amendment of Regulation 9 of the Principal Regulations
22.1. The Clause (1) of Regulation 9 of the Principal Regulations, the word
was proposed to be substituted
22.2. Comments have been received from TANGEDCO:
22.2.1. TANGEDCO has submitted that a proviso may be added under the clause
(1) of Regulation 9 such that in case of RE generators, for augmentation
of the ISTS, CTU shall also take into account of the Intra-State
transmission system planned and under execution to avoid redundant
transmission capacity and to develop such planned Intra-State
transmission system under Central financial Assistance.
22.3. Analysis and decision:
22.3.1. We agree with submission of TANGEDCO. The Commission has vide
notification dated 23.7.2018 published the CERC (Planning,
Coordination and Development of Economic and Efficient Inter-State
Transmission System by Central Transmission Utility and other related
matters) Regulations, 2018 wherein it has been provided that the CTU
shall carry out transmission planning for augmentation and strengthening
inter-alia considering existing and under-construction inter-State and
intra-State transmission network up to desired voltage level.
Hence, the concern raised by TANGEDCO has been duly considered by
the Commission.
Page 49
22.4. Based on above discussions,the Clause (1) of Regulation 9 of the
Principal Regulations shall be substituted with the
23. Amendment of Regulation 12 of the Principal Regulations:
23.1. In the Third Proviso to Clause (1) of Regulation 12 of the Principal
was proposed to be added after the words
23.1.1. The Commission had given following rationale while proposing the
above amendment:
5.1. Regulation 12 deals with the processing of applications for long
term access. The gestation period of renewable generating station is
very less in comparison to the transmission system and the criteria of
minimum 10% award of EPC contract by renewable energy generator to
start implementation of transmission project may leave very less time for
implementation of transmission system required for evacuation of
renewable power. 10% EPC will be done by the successful bidder.
Hence, it has been proposed that implementation of transmission system
associated with renewable generation may be taken up by the CTU in
consultation with CEA and MNRE even if EPC contract for 10% has not
been placed. CTU shall quarterly monitor the progress of renewable
energy generators and in case of adverse progress, CTU may review
implementation of transmission system.
5.2. Accordingly, in the 3rd proviso to Clause (1) of the Regulation 12 of
Renewable Energy generati
23.1.2. Comments have been received from MSEDCL, Greenko and
TANGEDCO:
(a) MSEDCL has suggested that 10% EPC condition shall not be waived for
Renewable Energy generating Station(s); otherwise separate Bank
Guarantee shall be taken from renewable Energy generating station
toward expected cost of transmission network required to be erected by
CTU for evacuation of power. This is to avoid unnecessary expenditure
from CTU, if generating station doesn't later on complete project, for which
transmission network developed.
Page 50
(b) Greenko has asked for approach to be adopted in case of Renewable
generation.
(c) TANGEDCO has stated that exception to RE generators will lead to
creation of redundant assets. The Stage-I connectivity applicants will
vanish after grant of connectivity due to their inability to acquire land,
financial closure and other issues. The asset created will become
redundant and will pose a huge financial burden to the existing DICs. This
has been witnessed in the case of green energy corridor being developed
for RE generators in Tuticorin area and the transmission corridors being
developed for solar power parks. Hence, in order to avoid creation of
redundant capacity, it is essential to have a check on the preparedness of
the RE promoters and hence, phasing of the transmission assets should
be matching with the commissioning of the RE generators. Considering
the huge RE capacity addition, this Clause is inevitable to safeguard the
interest of DISCOMS, end consumers as well as CTU. Further,
indemnification agreement is also essential to safeguard the interest of
CTU
23.1.3. Analysis and decision:
(a) MSEDCL and TANGEDCO have stated that 10% EPC value for
Renewable Energy generating Station(s) should not be waived off keeping
in view low gestation period of renewable energy generators vis-à-vis
transmission. We would like to clarify thatCentral Electricity Regulatory
Commission (Planning, Coordination and Development of Economic and
Efficient Inter-State Transmission System by Central Transmission Utility
and other related matters) Regulations, 2018 provide for regular matching
to ensure that redundant assets are not created and envisages wider
stakeholder participation. The reason for waiving of 10% EPC requirement
was adequately explained vide the draft amendment whereby we noted
that criteria of 10% award of EPC contract by renewable energy generator
to start implementation of transmission project may leave very less time
for implementation of transmission system for evacuation of renewable
power in view of less gestation period of renewable generating station in
comparison to the transmission system. Hence, CTU may take up
implementation of transmission system associated with renewable
Page 51
generation in consultation with CEA and MNRE even if EPC contract for
10% has not been placed. CTU shall quarterly monitor the progress of
renewable energy generators and in case of adverse progress, it may
review implementation of transmission system.
23.1.4. Accordingly, in the Third Proviso to Clause (1) of Regulation 12 of the
Energy generating Station(s) shall
.
23.2. In the Fifth Proviso to Clause (1) of Regulation 12 of the Principal
was proposed to
also that in cases where there is any material change in location of the
23.3. Comments have been received from SECI:
23.3.1. SECI has submitted that it has been noted in the Explanatory
Memorandum of the proposed draft that the implementing agency or
designated agency may find it difficult to indicate firm beneficiary /target
beneficiary in the applications for LTA prior to completion of Bid and they
can apply for LTA without indicating any beneficiary /region. SECI has
suggested that in case quantum (MW) change is more than 100MW or
40% of applied quantum (MW) then in line with proposed Connectivity
Regulations, Government nominated implementing agency will be
exempted for fresh LTA application.
23.4. Analysis and decision:
23.4.1. We agree with suggestion of SECI that it will not apply for target
region. The extant Regulations require all Applicants to indicate target
region and accordingly Renewable Energy Implementing Agency should
also indicate target region.
23.4.2. Further, the existing 5
th
proviso to Clause (1) of Regulation 12 of the
Connectivity Regulations provides for fresh applications for grant of LTA in
case of material change in location of the applicant or change in quantum
to be interchanged with ISTS by more than 100MW or change in region
from which electricity is to be procured or to which supplied. If the target
Page 52
region is not specified in the first instance, informing the same shall not be
considered under change of region. We note that Applicant covered under
2(1)(b)(i)(g) should also be covered under first proviso to Regulation 8(1).
Accordingly the same have been included in Regulation 8(1)There are
certain category of applicants for which fresh application for grant of LTA
shall be required if change in quantum to be interchanged with ISTS is
more than 40% of installed capacity. Accordingly, in the Fifth Proviso to
material change in location of the applicant or change by more than 100
23.5. A new Clause was proposed be added after Clause (1) of Regulation
12 of the Principal Regulations as under:
8, Stage-II Connectivity shall not be a pre-requisite for applying for
23.5.1. Comments have been received from Greenko, Indian Wind Energy
Association (InWEA), Indian Wind Power Association (IWPA), SECI
and TANGEDCO:
(a) Greenko has queried that whether the renewable generation applicant
can apply for LTA without Stage- 2 connectivity granted?
(b) Indian Wind Energy Association (InWEA) has suggested that this
provision needs be extended to the applicant covered under Regulation
2(1)(b)(i)(f) with proper controls.
(c) IWPA has submitted that adding a new clause which does not insist for
stage-II Connectivity as a pre-requisite for particular category of
applicants alone does not appear to be considering all applicants in the
Renewable Energy Sector on equitable footing. Condition for applying for
Stage-II involves substantial financial inputs by the applicants. Therefore,
not insisting Stage-II connectivity prior to applying for LTA in case of a
limited category of applicants only shall put the others under lot of
disadvantages specifically in competitive bidding scenarios. Therefore,
Page 53
this clause may be suitably amended to consider all applicants on
equitable footing to ensure fair opportunity for all interested players in the
Renewable Energy Sector.
(d) TANGEDCO has suggested that if the company or entity defined under
Regulation 2(l)(b)(i)(g) is relieved off the requisite for Stage-II
Connectivity, then without the mandatory requirements under Stage-II
Connectivity or even without any firm commitment from the RE
generators the agency acting on behalf of RE generators can apply for
LTA. This will lead to uncertainty in planning the transmission system and
also unjustifiable capital investment by the TSP and burden to
beneficiaries. Hence, the mandatory conditions under Stage-II
connectivity shall have to be fulfilled by the RE generators who avails
LTA through the Nodal agency or company acting on behalf of RE
generators.
23.5.2. Analysis and decision:
(a) In regard submissions, it is clarified that the
requirement of Stage-II for LTA has been done away with for all types of
Applicants.
(b) With regards to submissions of TANGEDCO, we note an Applicant can
apply LTA with Connectivity application or after Connectivity is granted.
Due safeguards are built in the Regulations to address the concerns of
revision of planned transmission system under CERC Planning
Regulations. The nodal agency may undertake revision in planned
transmission system, if required, to transmit power from renewable
generating station to the beneficiaries.
23.5.3. Based on above discussions, a new clause shall be added after
clause (1) of Regulation 12 as under:
anything to the contrary in the Procedure, Stage-
II Connectivity shall not be a pre-
24. Amendment of Regulation 13 of the Principal Regulations:
24.1. The First proviso of Regulation 13 of the Principal Regulations was
proposed to be deleted.
Page 54
24.1.1. The Commission had given following rationale while proposing the
above amendment:
6.1. The nodal agency for grant of Connectivity, long term access and
medium term open access is the CTU and hence, the CTU can approach
the Commission any time in case it faces any difficulty in implementation
of the provisions of these Regulations. Accordingly, the first proviso to
Clause (1) of the Regulation 13 has been deleted.
24.1.2. No comments have been received from the stakeholders on this
Regulation. Accordingly, 1
st
proviso of Regulation 13 of the Principal
Regulations shall be deleted.
24.2. The Clause (3) of Regulation 13 of the Principal Regulations was
proposed to be deleted.
24.2.1. The Commission had given following rationale while proposing the
above amendment:
6.2. The Commission vide notification dated 23.7.2018 issued the CERC
(Planning, Coordination and Development of Economic and Efficient Inter-
State Transmission System by Central Transmission Utility and other
related matters) Regulations, 2018. The objectives of the said Regulations
are as under:
ations - The objectives of this Regulation
are to:
(1) lay down the broad principles, procedures and processes to be
followed for planning and development of an efficient, co-ordinated,
reliable and economical system of inter-State transmission system
(ISTS) for smooth flow of electricity from generating stations to the
load centres;
(2) ensure wider participation of stakeholders in the planning process
participation;
(3) specify procedures to bring about transparency in the planning
process; and
(4) demarcate the roles and responsibilities of various organisations
6.3. Hence, the matters related to transmission planning,
coordination/consultation with stakeholders shall be dealt with under the
aforesaid Regulations. Accordingly, the Clause (3) of the Regulation 13 of
the Principal Regulations has been proposed to be deleted
24.2.2. Comments have been received from MSEDCL.
Page 55
(a) MSEDCL has submitted that the deletion of this provision is contradictory
to clause 7.2 of Detailed Procedure for grant of Connectivity to Projects
based on Renewable Sources to inter-State transmission system issued
vide order dated 15.5.2018. Hence, amendment needs to be made in
detail procedure of RE connectivity, so as to make provision in line with
provision under the CERC(Planning, Coordination and Development of
Economic and Efficient Inter-State Transmission System by Central
Transmission Utility and other related matters) Regulations, 2018.
24.2.3. Analysis and decision:
24.2.4. We have considered the submissions of MSEDCL.
the suggestions of the MSEDCL that the proposed amendment in 1
st
proviso to the Regulation 13 of the Connectivity Regulations is against the
Clause 7.2 of the Detailed Procedure for grant of Connectivity to Projects
based on Renewable Sources to inter-State transmission system issued
vide order dated 15.5.2018. the Clause 7.2 of the aforesaid detailed
procedure is reproduced as under:
7.2 New sub-stations for harnessing renewable generation potential
shall be planned by CTU in consultation with CEA, and Ministry of
New and Renewable Energy (MNRE) or its designated
agency/authority / nodal officer. CTU shall regularly interact with
MNRE or its designated agency / authority / nodal officer in this
regard. The sub-station plant shall be implemented in terms of the
tariff policy
24.2.5. We note that Clause 7.2 of the above said detailed procedure deals with
the planning of transmission system for harnessing renewable generation
potential by CTU in consultation with CEA and MNRE. Whereas the
existing Clause 3 of Regulation 13 of the Connectivity Regulations deals
with implementation of transmission system in accordance with the tariff
based competitive bidding process.
24.2.6. Further, the Clause 3 of Regulation 6 of the CERC (Planning,
Coordination and Development of Economic and Efficient Inter-State
Transmission System by Central Transmission Utility and other related
matters) Regulations, 2018 provides that while planning to augment ISTS
may have consultation with MNRE and the Departments responsible for
Page 56
renewable energy development of the State Governments. The said
Regulation 6(3) is reproduced as under:
(3) The Central Transmission Utility may have consultations, with
regard to renewable energy potential and its capacity addition, with
Ministry of New and Renewable Energy (MNRE), Government of India
or its authorized agencies and Departments responsible for renewable
energy development of the State Governments, in advance
24.2.7. Hence, the matters related to transmission planning,
coordination/consultation with stakeholders shall be dealt in accordance
with the CERC (Planning, Coordination and Development of Economic
and Efficient Inter-State Transmission System by Central Transmission
Utility and other related matters) Regulations, 2018.
24.2.8. Based on the above discussions, Clause (3) of Regulation 13 of the
Principal Regulations shall be deleted.
25. Amendment of Regulations 15 and 21 of the Principal Regulations:
25.1. The Regulation 15 and Regulation 21 of the Principal Regulations were
proposed to be substituted to include para numbering.
25.2. The Commission had given following rationale while proposing the
above amendment:
7. The Regulations 15 and 21 of the Principal Regulations have been
proposed to be amended as per the draft Regulations for the purpose of
clarity without changing the intent of these Regulations.
25.3. No comments have been received from the stakeholders on this
Regulation.
25.4. Analysis and decision:
25.4.1. The proposed amendments (para numbering) in the Regulation 15 and in
2
nd
proviso to clause (1) of Regulation 21 of the Connectivity Regulations
have been done for purpose of clarity. The intent of these regulations has
not been changed.
26. Amendment of Regulation 27 of the Principal Regulations:
26.1. The First proviso of sub-clause (c) of Clause (2) of Regulation 27 of the
Principal Regulations was proposed to be substituted as under:
Page 57
transmission
elements shall be consistent with the timeline for completion of
projects as specified in the relevant Tariff Regulations issued by the
Commission from time to time
26.2. No comments have been received from the stakeholders on this
Regulation.
26.3. Analysis and decision:
26.3.1. The timeline for construction of projects have not been included in draft
Tariff Regulations 2019-24.
26.4. Based on the above discussion above discussions, following
amendment is proposed:
26.4.1. The sub-clause (c) of Clause (2) of Regulation 27 of the Principal
Regulations shall be deleted
27. Amendment of Regulation 29 of the Principal Regulations:
27.1. The Regulation 29 was proposed to be deleted.
27.2. The Commission had given following rationale while proposing the
above amendment
8. The Commission vide order dated 29.4.2011 inter alia approved the
Billing, Collection and Disbursement Procedure under Central Electricity
Regulatory Commission (Sharing of Transmission Charges and Losses),
Regulations, 2010 which govern the matters related to payment of inter-
State transmission charges and losses. Further, vide notification dated
18.5.2015, the Commission issued the CERC (Fees and Charges of
Regional Load Despatch Centres and other related matters) Regulations,
2015 which is applicable for determination of fees and charges to be
collected by RLDCs from generating companies, DISCOMs, ISTS
Licensees, buyers, sellers and ISTS trading licensees. In view of the
aforesaid, the Regulation 29 of the Principal Regulations, which provides
for payment of transmission charges and fees and charges for the
Regional Load Dispatch Centre, has been proposed to be deleted.
27.3. No comments have been received from the stakeholders on this
Regulation.
27.3.1. Accordingly, The Regulation 29 shall be deleted.
Page 58
28. Additional comments:
28.1. CTU vide letter dated 5.12.2018has suggested to allow rectification of
deficiency by an Applicant under these Regulations as allowed for
Renwable projects under detailed Procedure dated 15.5.2018. A separate
Clause (5A) has been added after regulation 5 to include the Clauses as
per detailed procedure dated 15.5.2018.
28.2. IWTMA has submitted that clause ed Procedure
for grant of Connectivity to Project based on Renewable Sources to inter-
State Transmission System provides that the developer of renewable
generation project shall comply with requirements specified at Clause
16.4 of CEA Manual on Transmission Planning Criteria 2013, with regard
to requirement of reactive compensation at the pooling station. CTU while
conveying grant of connectivity stipulates that the wind developers shall
provide adequate reactive power compensation so that under all dispatch
scenarios power factor of 0.98 shall be maintained at injection point.
IWTMA has submitted that the stipulations regarding maintaining power
factor of 0.98 absorbing at injection point under all dispatch scenarios is
for Planning Purpose. The dispatch scenarios in the planning criteria are
with reference to light load conditions and peak load conditions of the
system and relatable dispatches of the generating stations. It is
technically not feasible to maintain power factor of 0.98 absorbing under
insignificantly very low generation despatches, below a generation
dispatch of say 20% of the connected capacity of the generating station.
Further, the Central Electricity Authority (Technical Standards for
connectivity to the Grid)Regulations (amendment of October, 2013)
provide that the power factor of the generating station should lie between
the limits of 0.95 lag (export) and 0.95 lead(absorbing).
28.3. We have considered the submission of IWTMA. The clause 16.4 of the
CEA Manual on Transmission Planning Criteria provides as under:
(absorbing) at their grid inter-connection point for all dispatch
scenarios by providing adequate reactive compensation and the
same shall be assumed for system stud
Page 59
28.4. Clause 12.2.2 (iv) of the Detailed Procedure for grant of Connectivity to
Project based on Renewable Sources to inter-State Transmission System
provide as under:
The developer of renewable generation project shall
comply with requirements specified at Clause 16.4 of CEA Manual on
Transmission Planning Criteria 2013, with regard to requirement of
reactive compensation at the pooling station
28.5. Also CEA (Technical Standard for Connectivity) (Amendment)
Regulations, 2013 provide as under
"B2. For generating station getting connected on or after completion
of 6 months from date of publication of these Regulations in the
Official Gazette,
(1) The generating station shall be capable of supplying
dynamically varying reactive power support so as to maintain power
factor within the limits of 0.95 lagging to 0.95 leading.
(2) The generating units shall be capable of operating in the
frequency range of 47.5 Hz to 52 Hz and shall be able to deliver
rated output in the frequency range of 49.5 Hz to 50.5 Hz.
Provided that above performance shall be achieved with
voltage variation of up to ±5% subject to availability of
commensurate wind speed in case of wind generating stations and
28.6. We have perused the provision regarding power factor as provided in the
CEA (Technical Standard for Connectivity) (Amendment) Regulations,
2013 and CEA Manual on Transmission Planning Criteria. It is observed
that the requirement of power factor of 0.98 (absorbing)at grid inter-
connection point for all dispatch scenarios by providing adequate reactive
compensation is for the purpose of transmission planning and hence the
same shall be considered for planning transmission system. Further, for
all operation purpose, CEA (Technical Standard for Connectivity)
(Amendment) Regulations, 2013 provide that generating station shall be
capable of supplying dynamically varying reactive power support so as to
maintain power factor within the limits of 0.95 lagging to 0.95 leading.
Therefore, for all operational purpose, the limits of 0.95 (lagging) to 0.95
(leading) as provided in the CEA (Technical Standard for Connectivity)
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(Amendment) Regulations, 2013 shall be used. Necessary changes shall
be brought out in detailed procedure in due course.
28.7. Stakeholders have suggested amendments on certain issues not covered
grant of Connectivity to projects based on Renewable source of energy to
inter-State
stakeholders and shall be kept in view while proposing future amendment
to the Connectivity Regulations.
Sd/- Sd/-
(M.K. Iyer) (P.K. Pujari)
Member Chairperson
Page 61
Appendix-I
List of stakeholders submitted their written comments/suggestions:
Sl. No.
Name of Stakeholder
1.
Adani Green Energy Ltd. (AGEL)
2.
EDEN Renewable Cite Private Ltd
3.
GREENKO
4.
GRIDCO
5.
Gujarat Fluorochemicals Limited
6.
IL&FS Energy Development company Limited
7.
Indian Wind Energy Association (InWEA)
8.
Indian Wind Power Association (IWPA)
9.
Indian Wind Turbine Manufactures Association (IWTMA)
10.
Inox Wind Infrastructure Services Ltd
11.
Maharashtra State Electricity Distribution Company Ltd (MSEDCL)
12.
National Solar Energy Federation of India (NSEFI)
13.
NTPC
14.
POWERGRID
15.
Solar Energy Corporation of India Ltd (SECI)
16.
The Energy and Research Institute (TERI)
17.
TANGEDCO
Page 62
Appendix-II
List of Stakeholders given comments/suggestions during Public Hearing held
on 19.09.2018
Sl. No.
COMPANY/STAKEHOLDER/INDIVIDUAL
1.
TANGEDCO
2.
GRIDCO
3.
Adani Green Energy Ltd.
4.
POWERGRID
